Exhibit 99.5

Exception Ratings

AMC Loan ID

Exception Type

Exception Category

Exception Subcategory

Exception

Exception Detail

Exception Information

Compensating Factors

Follow-up Comments

Cleared Date

Unable To Clear Date

Cured Date

Waived Date

Exception Level Grade

Note Date

Property State

Occupancy

Purpose

Exception Remediation

DBRS Initial Exception Rating

DBRS Final Exception Rating

Fitch Initial Exception Rating

Fitch Final Exception Rating

Kroll Initial Exception Rating

Kroll Final Exception Rating

Moody's Initial Exception Rating

Moody's Final Exception Rating

S&P Initial Exception Rating

S&P Final Exception Rating

Originator QM ATR Status

TPR QM ATR Status

Is Curable

Overall Initial  Loan Grade

Overal Final  Loan Grade

200900982

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.83610% or Final Disclosure APR of 6.83600% is in excess of allowable threshold of APOR 3.15% + 2.5%, or 5.65000%.  Compliant Higher Priced Loan.

All fees have been verified as entered.  Used index value provided of 1.2695%.  The loan is designated as a higher priced loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

C

200900982

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller paid fees are reflected on the Seller's CD only.

Reviewer Comment (2016-10-20): Captured Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

C

200900982

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Final Closing Disclosure reflects $2,659.56 credit for increase in Total Closing Costs exceeded the legal limit.; however, cure for various 0% and 10% violations total $4,741.71.

Reviewer Comment (2016-09-29): Loan amount increased and subsequent discount point rebaselined with CoC.  No violation.

09/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

C

200900982

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $237.28 exceeds tolerance of $210.28 plus 10% or $231.31 (0)

Recording Fees were disclosed as $210.28 on Closing Disclosure dated[MM/DD/YYYY], but disclosed as $237.28 on Final Closing Disclosure.

Reviewer Comment (2016-09-29): Cured at closing.

09/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

C

200900982

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Final Closing Disclosure reflects $2,659.56 credit for increase in Total Closing Costs exceeded the legal limit.; however, cure for various 0% and 10% violations total $4,741.71.

Reviewer Comment (2016-09-29): Loan amount increased and subsequent discount point rebaselined with CoC.  No violation.  All other violations cured at closing.

09/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

C

200900982

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $6,229.34 exceeds tolerance of $1,659.75. (7200)

Fee was disclosed as $1,659.76 on the Initial CD, dated [MM/DD/YYYY], but disclosed as $6,229.34 on Final Closing Disclosure.

Reviewer Comment (2016-09-29): Loan amount increased and subsequent discount point rebaselined with CoC.  No violation.  All other violations cured at closing.

09/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

C

200900982

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $6,134.00 exceeds tolerance of $5,988.88. (8304)

Fee disclosed as $5,988.88 on Initial CD dated [MM/DD/YYYY], but disclosed as $6,134 on Final Closing Disclosure.

Reviewer Comment (2016-09-29): Loan amount increased and subsequent discount point rebaselined with CoC.  No violation.  All other violations cured at closing.

09/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

C

200900982

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

There is no evidence in the loan documents that the interim disclosure was received by the applicant at least three days prior to closing.

Reviewer Comment (2016-11-09): There is nothing in TRID that permits the creditor to disregard the additional three day delay requirements simply because the APR increased in excess of the accuracy tolerance but then decreased on the same day. Reviewer Comment (2016-11-04): The second that the disclosure with the higher APR is presented to the borrower, then the 3 day timing comes into effect, regardless of subsequent disclosures reflecting the lower APR. Reviewer Comment (2016-09-22): The issue on this CD isn't the receipt date, but rather that the APR on the 8/24 CD is 6.988% which is more than .125% higher than the previous CD APR of 6.836%, also issued 8/24.  Due to the higher APR, the borrower must be given an additional 3 days to review disclosure prior to closing. Seller Comment (2016-09-22): Lender sent in proof of delivery.

3

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

C

C

C

C

C

C

C

C

C

Higher Priced QM

Higher Priced QM

No

C

C

200900982

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Required reserves of 6 months per product guideline = $25,151.58.  Reserves verified after closing are $25,000.71 which is short of the six month requirement by $150.87.

677 representative FICO score >660 guideline minimum - 17 points above guideline minimum 27% DTI on this full documentation loan < 43% guideline max Borrower on this full documentation loan has a disposable income of $12,257.53

Reviewer Comment (2016-10-18): Client elects to waive. Reviewer Comment (2016-10-12): Rebuttal asks which document is being used for calculations.  All cals based on Final CD.  Rebuttal reflects cash to close of $98.312.02 in the reserve calculations.  Per final CD, cash to close required is $100,431.72 ($19,934.72 Cash to Close plus $80,497 Deposit).  Verified Assets of $125,432.43 - CTC of $100,431.72 = Cash available for reserves of $25,000.71, which is short the requirement by $150.87. Buyer Comment (2016-10-12): [MM/DD/YYYY]: With the Underwriting's confirmation of Assets Required, submitted a calculated assets Rebuttal LOE Pkg for AMC review and consideration. JF

10/18/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

BW

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

C

200900982

Credit

Credit

Misc

Credit Exception:

Lender approved exception in file to Underwrite to the new guidelines dated[MM/DD/YYYY] to utilize the acceptance of the Private VOR.

677 representative FICO score >660 guideline minimum - 17 points above guideline minimum

Reviewer Comment (2016-09-14): Lender waived exception.

09/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

BW

B

B

B

Higher Priced QM

Higher Priced QM

No

C

C

200900982

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

Approved exception in file to utilized[MM/DD/YYYY] guidelines which require a desk review.

677 representative FICO score >660 guideline minimum - 17 points above guideline minimum

Reviewer Comment (2016-09-21): Client elects to waive.

09/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

BW

B

B

B

Higher Priced QM

Higher Priced QM

No

C

C

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/73051)

Note is 5.625% with a $3682.74 P&I payment while the CD is 5.375% with a $3582.40 P&I payment.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Interest Rate that does not match the actual interest rate for the loan. (Final/[MM/DD/YYYY])

Note is 5.625% with a $3682.74 P&I payment while the CD is 5.375% with a $3582.40 P&I payment.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate Max Rate

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on[MM/DD/YYYY] with an increasing interest rate disclosed a maximum interest rate that does not match the actual maximum rate for the loan. (Final/[MM/DD/YYYY])

Note is 5.625% with a $3682.74 P&I payment while the CD is 5.375% with a $3582.40 P&I payment.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Max Amount

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on[MM/DD/YYYY] with an increasing payment disclosed the maximum possible amount of principal and interest that does not match the actual maximum amount for the loan. (Final/[MM/DD/YYYY])

Note is 5.625% initial rate while the CD is 5.375% initial rate

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

note rate does not match CD rate.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Principal and Interest

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Principal and Interest Payment that does not match the actual payment for the loan. (Final/[MM/DD/YYYY])

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/73052)

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/73053)

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/73054)

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 2 that does not match the actual maximum payment for the loan. (ProjSeq:2/73052)

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 3 that does not match the actual maximum payment for the loan. (ProjSeq:3/73053)

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 4 that does not match the actual maximum payment for the loan. (ProjSeq:4/73054)

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Min Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/73051)

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Disclosed TIP of 103.875 does not match calculated TIP of 105.380

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-10-24): No violation due to VCC.

10/24/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

Reviewer Comment (2016-10-13): Received evidence that disclosure was received within timing requirements. Buyer Comment (2016-10-11): 10/11 - Rebuttal letter showing disclosure sent on [REDACTED] as well as opened and viewed by borrower on [REDACTED].

10/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Reviewer Comment (2016-10-24): Received Valid CoC showing fees changed when program did.

10/24/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00. (7580)

Reviewer Comment (2016-09-29): Cured with $102.00 lender credit at closing

09/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AIR Table Maximum Interest Rate

TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Maximum Interest Rate that does not match the actual maximum interest rate for the loan. (Final/[MM/DD/YYYY])

note rate does not match CD rate.

Reviewer Comment (2016-12-29): Received attestation and documentation that the 5.675% was the incorrect note.  Borrower executed correct note with rate of 5.375%.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $855.00 exceeds tolerance of $595.00. (73196)

Reviewer Comment (2016-10-24): Received Valid CoC showing fees changed when program did.

10/24/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200954187

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $450.00. (7506)

Reviewer Comment (2016-09-29): Cured with $102.00 lender credit at closing

09/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200964888

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception.

Borrower on this Full documentation loan has a disposable income of $7547, exceeding the minimum requirement of $3700 by $3847 Mortgage Payment History:  Guideline requires a 12 month history with 0x30.  Borrower has a 26 month mortgage history with 0x30.

Reviewer Comment (2016-10-10): Client elects to waive.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

200964888

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.58590% or Final Disclosure APR of 6.58600% is in excess of allowable threshold of APOR 3.49% + 2.5%, or 5.99000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200964888

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.58590% or Final Disclosure APR of 6.58600% is in excess of allowable threshold of APOR 3.49% + 2.5%, or 5.99000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-10-07): Lender cured on post consummation CD dated [MM/DD/YYYY] with a corrected closing date.

10/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Reviewer Comment (2016-10-14): Contact is a CS Rep and is not required to have an NMLS. Buyer Comment (2016-10-14): [MM/DD/YYYY]: Submitted contact NMLS rebuttal to AMC for consideration. JF

10/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200964888

Credit

Credit

Misc

Credit Exception:

Missing guideline required Desk Review

Borrower on this Full documentation loan has a disposable income of $7547, exceeding the minimum requirement of $3700 by $3847 Mortgage Payment History:  Guideline requires a 12 month history with 0x30.  Borrower has a 26 month mortgage history with 0x30.

Reviewer Comment (2016-10-10): Client elects to waive.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $.00. (75103)

Reviewer Comment (2016-10-07): Lender cured on the final CD with a $152 tolerance cure.

10/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00. (7580)

Reviewer Comment (2016-10-07): Lender cured on the final CD with a $152 tolerance cure.

10/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $3,455.00 exceeds tolerance of $3,081.00 plus 10% or $3,389.10 (0)

Based on Lender's tolerance comparison, lender did not include the Escrow fees correctly in the 10% tolerance calculation.  Escrow agent reflected on SSPL and inclusion of fees in the 10% tolerance, tolerance is exceeded with no cure indicated.

Reviewer Comment (2016-11-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Reviewer Comment (2016-11-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200964888

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Escrow agent reflected on SSPL and Escrow fees incorrectly in section C versus section B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200964890

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.14290% or Final Disclosure APR of 8.14300% is in excess of allowable threshold of APOR 3.49% + 1.5%, or 4.99000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200964890

Compliance

Compliance

Federal Compliance

TILA NMLSR - Individual Originator NMLS information on documents does not match NMLS website

Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator NMLSR information on loan documents does not match NMLSR.

1003 Lists and the website lists

Reviewer Comment (2016-12-06): Received copies of updated documents reflecting correct broker/NMLS number.

12/06/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

200964890

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200964890

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-10-10): Lender cured on post consummation CD dated[MM/DD/YYYY] with corrected closing date of[MM/DD/YYYY].

10/10/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

200964890

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD lists $47791.22 in seller paid fees and the buyer CD lists $20745.24 in seller paid fees.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200964890

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200964890

Credit

Credit

Misc

Credit Exception:

Missing guideline required Desk Review

73 months reserves 70% LTV is less than max allowed

Reviewer Comment (2016-10-10): Client elects to waive.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

200964890

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00. (7580)

Reviewer Comment (2016-10-10): Lender cured on post consummation CD dated[MM/DD/YYYY] with a $2 tolerance cure and dated same day as disbursement so no actual charge to the borrower and CD provided by title agent to borrower as evidence by borrower signature.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200964890

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower:

Missing guideline required 2015 S Corp Tax Transcripts, only 2013 & 2014 found in file  Lender approved exception.

73 months reserves 70% LTV is less than max allowed

Reviewer Comment (2016-10-10): Client elects to waive.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

200964890

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-10-10): Lender cured on post consummation CD dated[MM/DD/YYYY] with a $2 tolerance cure and dated same day as disbursement so no actual charge to the borrower and CD provided by title agent to borrower as evidence by borrower signature.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200964890

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Reviewer Comment (2016-10-10): Lender cured on post consummation CD dated[MM/DD/YYYY] with a $2 tolerance cure and dated same day as disbursement so no actual charge to the borrower and CD provided by title agent to borrower as evidence by borrower signature.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200964890

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID non-compliant.  Post consummation CD with an issue date of[MM/DD/YYYY] is executed by the borrowers on[MM/DD/YYYY].  Post consummation CD also reflects fees paid by the seller that were not reflected on prior final CD.

Reviewer Comment (2016-10-25): The 9/22 is considered the Final CD and used for all testing and no signature requirement on post close CDs.

10/25/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

200964895

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.36660% or Final Disclosure APR of 7.38600% is in excess of allowable threshold of APOR 3.64% + 1.5%, or 5.14000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200964895

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 7.36660% or Final Disclosure APR of 7.38600% is in excess of allowable threshold of APOR 3.64% + 1.5%, or 5.14000%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200964895

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200964895

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Issue Date Not Provided

TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on[MM/DD/YYYY] did not disclose the actual Date Issued. Compliance testing may be unreliable using an estimated Date Issued based on best information available. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-10-28): Received attestation that CD was issued from title and never presented to borrower. Buyer Comment (2016-10-27): please disregard the first entry's, due to needed information that I wanted to add the second upload is perfect.

10/28/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

200964895

Compliance

Compliance

State Compliance

(State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided)

Maryland Higher-Priced Mortgage Loan:  Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for.

Reviewer Comment (2016-10-12): Received copy of executed disclosure. Buyer Comment (2016-10-12): [MM/DD/YYYY] Was able to locate Maryland Loan Disclosure that was in question and is now uploaded.

10/12/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

200964895

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200964895

Credit

Credit

Credit Eligibility

Guideline Issue:  Foreclosure timeline outside of credit guidelines

Deed in Lieu < 2 year required seasoning from application date.  Lender approved exception.

Residual income of $3,286 in excess of required $1,200 DTI of 30.606% < 43% 54% < 75% maximum LTV

Reviewer Comment (2016-10-10): Client elects to waive.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

200964895

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Refinance purpose discrepancy.

Lender used alternate tradelines on a cash-out refinance.  Per guidelines only Purchase and Rate/Term transactions are eligible for alternate tradeline usage.

Residual income of $3,286 in excess of required $1,200 DTI of 30.606% < 43% 54% < 75% maximum LTV

Reviewer Comment (2016-10-10): Client elects to waive.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

200964895

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Issue Date Not Provided

TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on  [MM/DD/YYYY] did not disclose the actual Date Issued. Compliance testing may be unreliable using an estimated Date Issued based on best information available. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-10-28): Received attestation that CD was issued from title and never presented to borrower. Buyer Comment (2016-10-27): please disregard the first entry's, due to needed information that I wanted to add the second upload is perfect.

10/28/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

200964895

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Issue Date Not Provided

TILA-RESPA Integrated Disclosure: Closing Disclosure estimated to be provided on[MM/DD/YYYY] did not disclose the actual Date Issued. Compliance testing may be unreliable using an estimated Date Issued based on best information available. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-10-28): Received attestation that CD was issued from title and never presented to borrower. Buyer Comment (2016-10-27): please disregard the first two entry's, due to needed information that I wanted to add the third upload is perfect.

10/28/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

200964895

Credit

Credit

Misc

Credit Exception:

Missing guideline required Desk Review

Residual income of $3,286 in excess of required $1,200 DTI of 30.606% < 43% 54% < 75% maximum LTV

Reviewer Comment (2016-10-10): Client elects to waive.

10/10/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

200964895

Property

Property - Appraisal

Appraisal Reconciliation

Value variance greater than 10% between origination appraisal and subsequent product

Reviewer Comment (2017-03-20): A Field review supporting the original appraisal value was ordered and received.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

200967222

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Reviewer Comment (2016-11-15): Received copy of VOR.

11/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200967222

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.79070% or Final Disclosure APR of 6.80400% is in excess of allowable threshold of APOR 3.15% + 2.5%, or 5.65000%.  Compliant Higher Priced Loan.

Valid exception.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200967222

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.79070% or Final Disclosure APR of 6.80400% is in excess of allowable threshold of APOR 3.15% + 2.5%, or 5.65000%.  Compliant Higher Priced Loan.

Valid exception.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200967222

Compliance

Compliance

Federal Compliance

ARM Disclosure Status

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.

Valid exception.

Reviewer Comment (2016-12-02): Received evidence that borrower received disclosure within timing requirements.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200967222

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200984643

Credit

Credit

Misc

Credit Exception:

Lender used $ of employer bonus advancement for liquid funds to close. Lender approved exception.

Borrower on this Full documentation loan has a disposable income of $12,647.63 Borrower has job stability for 15.92 years as an [REDACTED] in the current job with 15 years in the [REDACTED] industry. 748 representative FICO score > 680 guideline minimum - 68 points above guideline minimum

Reviewer Comment (2016-10-27): Client elects to waive.

10/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

200984643

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200984643

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-10-28): Received evidence that disclosure was received within timing requirements.

10/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

200984643

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-11-29): Lender contact is a CS Rep and doesn't have a unique identifier.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200984643

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure. Title - Escrow Fee $2635.70, Title - Messenger Fee $20.00, Title - Sub Escrow Fee $62.50, Title - Wire Fee $20.00, Home Warranty $450.00, NHD $80.00, and Reimbursement for Building Report $299.00 were reflected on the Seller's CD, however were not reflected on the Borrower's Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200984643

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-11-03): Received evidence that borrower received disclosure within timing requirements.

11/03/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

200984643

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68290% or Final Disclosure APR of 5.68300% is in excess of allowable threshold of APOR 3.17% + 2.5%, or 5.67000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200984643

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68290% or Final Disclosure APR of 5.68300% is in excess of allowable threshold of APOR 3.17% + 2.5%, or 5.67000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200984643

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200984657

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.63150% or Final Disclosure APR of 6.63200% is in excess of allowable threshold of APOR 3.19% + 1.5%, or 4.69000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-10-31): Evidence that borrowers received disclosure within timing requirements.

10/31/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-28): Received evidence that borrower received disclosure within timing requirements.

11/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Erroneous Reg ID 3062.  No tolerance violation of (Transfer Tax fee) due to this fee was seller paid, and is customarily paid by Seller in the state of (FL).

Reviewer Comment (2016-11-04): Erroneous Reg ID 3062. No tolerance violation of (Transfer Tax fee) due to this fee was seller paid, and is customarily paid by Seller in the state of (FL).

11/04/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $490.00 exceeds tolerance of $450.00. (7506)

Fee disclosed as ($450.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($490.00) on Final Closing Disclosure.

Reviewer Comment (2016-10-26): Cure provided on Final CD.

10/26/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $28.50 exceeds tolerance of $20.00. (7520)

Fee disclosed as ($20.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($28.50) on Final Closing Disclosure.

Reviewer Comment (2016-10-26): Cure provided on Final CD.

10/26/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00. (7580)

Fee disclosed as ($90.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($92.00) on Final Closing Disclosure.

Reviewer Comment (2016-10-26): Cure provided on Final CD.

10/26/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $4,282.50 exceeds tolerance of $1,722.00. (8304)

Erroneous Reg ID 3060.  This fee was seller paid, and is customarily paid by Seller in the state of (FL).

Reviewer Comment (2016-11-04): This fee was seller paid, and is customarily paid by Seller in the state of (FL).

11/04/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

Prepaid Interest was disclosed as ($53.22) per day for (1) days for a total of  ($47.81), however this would equate to total paid of ($53.22).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 2933.  No tolerance violation of (Transfer Tax fee) due to this fee was seller paid, and is customarily paid by Seller in the state of (FL).

Reviewer Comment (2016-11-04): This fee was seller paid, and is customarily paid by Seller in the state of (FL).

11/04/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

200984657

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure. Title - Abstract Fee $100.00, Attorney Fee $595.00, Courier Fee $25.00, Lien Search $270.00, Wire Fee $28.00, and Wire Fee $28.00 were reflected on the Seller's CD, however were not reflected on the Borrower's Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200984657

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

Borrower on this (Full) documentation loan has a disposable income of $3,525.51 71.87% LTV < 85 guideline max -  $31,800 more equity than required by program guidelines 9.97 months reserves > 3 months guideline minimum - borrowers have verified reserves of $22,570.08

Reviewer Comment (2016-10-27): Client elects to waive.

10/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

200984657

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Total debt ratio discrepancy.

Lender approved exception. Calculated DTI of 48.83469 exceeds Guideline total of 43% with non-occupying co borrower.

Borrower on this (Full) documentation loan has a disposable income of $3,525.51 71.87% LTV < 85 guideline max -  $31,800 more equity than required by program guidelines 9.97 months reserves > 3 months guideline minimum - borrowers have verified reserves of $22,570.08

Reviewer Comment (2016-10-27): Client elects to waive.

10/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

200993030

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200993030

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.23020% or Final Disclosure APR of 7.31400% is in excess of allowable threshold of APOR 3.11% + 2.5%, or 5.61000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200993030

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-16): Received evidence that borrower received disclosure within timing requirements.

11/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200993030

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200993030

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TIP of (139.008%) but calculated TIP is (137.500%).  Used Index Value = (1.539%) per (Loan Transmission Form) document in file.

Reviewer Comment (2016-11-23): Data correct on subsequent CDs (SFIG).

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200993030

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for 10% tolerance violation ($427.00) was not provided.

Reviewer Comment (2016-11-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200993030

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $515.00 exceeds tolerance of $80.00 plus 10% or $88.00 (0)

(Title - Doc Prep and Title - Post Closing fees(s)) was not disclosed on Loan Estimate. Unable to determine if obligatory seller paid fee or if should be considered a borrower fee paid by seller.

Reviewer Comment (2016-11-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2016-11-02): The lender states that the fee was not listed on sales contract (seller didn't offer to pay).  Since not a contractually obligated seller paid fee, the fee would be an buyer fee that the seller ended up paying.  Violation is valid.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200993030

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Cure for 10% tolerance violation ($427.00) was not provided.

Reviewer Comment (2016-11-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2016-11-02): The lender states that the fee was not listed on sales contract (seller didn't offer to pay).  Since not a contractually obligated seller paid fee, the fee would be an buyer fee that the seller ended up paying.  Violation is valid.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996855

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.30450% or Final Disclosure APR of 7.32900% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996855

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2016-11-10): Designation switched to Non-QM

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996855

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Guideline maximum of 50% exceed.

Reviewer Comment (2016-11-10): Designation switched to Non-QM

11/10/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996855

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996855

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.30450% or Final Disclosure APR of 7.32900% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996855

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final Closing Disclosure issued on [MM/DD/YYYY] with a Closing date of [MM/DD/YYYY] and a disbursement date of [MM/DD/YYYY]. Mortgage notary/consummation date is [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200996855

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Loan Type

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Loan Type that does not match the actual loan type for the loan. (Final/[MM/DD/YYYY])

Closing Disclosure reflects loan type as Other-High Balance.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200996855

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Natural Hazard.  Fee Amount of $123.95 exceeds tolerance of $.00. (75142)

Title-Natural Hazard Fee was not disclosed on LE dated [MM/DD/YYYY], but disclosed as $123.95 on Final Closing Disclosure.

Reviewer Comment (2016-11-07): Per Purchase Contract, fee is seller's responsibility.   No violation.

11/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200996855

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2016-11-09): Received copy of fraud report.

11/09/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996855

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996855

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrowers' departure residence s pending sale per application.  Documentation of sale prior to or on the closing date was not provided. Lender qualified using W2 income from a company that is owned 100% by the borrower. DTI including this housing debt and self employment income from tax returns results in a DTI of 64.67304% which exceeds guidelines maximum of 50%.

Reviewer Comment (2016-11-10): Proof of sale of departing residence was provided.

11/10/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996855

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

File includes gift letters for $ Letter in file on  indicates that the gift funds are to be wired to closing.  The Final Closing disclosure, however, only reflect n deposits. Provide documentation of source of funds used for closing.

Reviewer Comment (2016-12-21): Received all required asset statements and verification.

12/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996855

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Loan Estimate dated [MM/DD/YYYY] (page 1197) shows a $fee under section H that is not identified.

Reviewer Comment (2016-11-07): Data correct on subsequent disclosures.

11/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996855

Credit

Assets

Asset Documentation

Asset Issue:  Gift funds are missing evidence of receipt

Reviewer Comment (2016-12-20): Lender attests that only 2 of the 4 gifts are being used since there is no evidence of receipt of the other 2.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996855

Credit

Credit

Misc

Credit Exception:

A Gift in the amount of $ was made to the borrower's business and not the borrowers.

Reviewer Comment (2016-11-10): Gift was transferred to personal account.

11/10/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996855

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Borrower on this full documentation loan has a disposable income of $4720

Reviewer Comment (2016-12-08): Client elects to waive.

12/08/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

200996861

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Payment Shock exceeds credit guidelines.

The guidelines reflect first time homebuyers may not exceed a 250% payment shock. The borrowers' payment shock is 292.81869%.

Borrower has a disposable income of $3775.08

Reviewer Comment (2016-11-02): Client elects to waive.

11/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Secondary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.01010% or Final Disclosure APR of 7.01000% is in excess of allowable threshold of APOR 3.21% + 1.5%, or 4.71000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

Federal Compliance

Initial Loan Application Status Test

No evidence of application date located in file.  Compliance tests were run using an application date of  which is the consummation date.  A 1 month lookback was used to determine this application date.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

State Compliance

Maryland Counseling Agencies Disclosure Not in File

Maryland HB1399 - No evidence of counseling agencies list per Maryland HB 1399.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

State Compliance

(State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided)

Maryland Higher-Priced Mortgage Loan:  Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for.

Reviewer Comment (2016-11-25): Received evidence that borrower received disclosure within timing requirements.

11/25/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 7.01010% or Final Disclosure APR of 7.01000% is in excess of allowable threshold of APOR 3.21% + 1.5%, or 4.71000%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-07): Received evidence that borrower received disclosure within timing requirements.

11/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

200996861

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $520.00 exceeds tolerance of $500.00. (7506)

Reviewer Comment (2016-10-31): Cured on closing CD

10/31/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200996861

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-02): Lender contact is a CS Rep and doesn't have a unique identifier.

11/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

200996861

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

200996863

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Missing Lease agreements on two rental properties. Exception approved page 240-241

Guideline variance approved by lender at time of origination. The residual income 43680.54 is above the required amount of $2700 and PITIA payment decreasing from $4926.82 to $3887.43 page 240

Reviewer Comment (2016-10-31): Client elects to waive.

10/31/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

200996863

Credit

Credit

Credit Calculation / Analysis

Guideline Issue:  Insufficient tradelines per credit guidelines

0 trade lines < 3 minimum requirement per guidelines.

Reviewer Comment (2016-11-09): Guidelines only require 2 open trade lines.  this has been met.

11/09/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996863

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996863

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Secondary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996863

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.62760% or Final Disclosure APR of 7.63700% is in excess of allowable threshold of APOR 3.49% + 2.5%, or 5.99000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996863

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996863

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-23): Received attestation that 9/20 disclosure was produced by title and never presented to borrower. Reviewer Comment (2016-11-16): Document provided is 9/21 CD.  Missing evidence of receipt of 9/20 CD. Reviewer Comment (2016-11-09): Unable to locate any documents uploaded for this exception.

11/23/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996863

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996863

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Reviewer Comment (2016-11-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996863

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Origination Fee.  Fee Amount of $8,740.00 exceeds tolerance of $.00. (7325)

Reviewer Comment (2016-11-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996863

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on[MM/DD/YYYY], prior to three (3) business days from transaction date of[MM/DD/YYYY].

Reviewer Comment (2016-11-09): Data correct on subsequent CDs.

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996863

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2016-11-07): Qualification method corrected.  ATR is met.

11/07/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996864

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.74990% or Final Disclosure APR of 5.83100% is in excess of allowable threshold of APOR 3.20% + 2.5%, or 5.70000%.  Non-Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996864

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of Non QM Fail.

Reviewer Comment (2016-11-07): Qualification method corrected.  ATR is met.

11/07/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Monthly Payment - Interest-Only

Ability-to-Repay (Dodd-Frank 2014): Improper calculation method used for Non QM qualifying monthly payment (interest-only loan with no balloon payment due within first five (5) years).

P&I Payment in Projected Payments section of the final CD inaccurate - calculated Projected Payments table reflects interest only payments up to year 10 in column 2 per Note terms (10 year IO period), final CD reflects interest only payments in all columns (1-4). Lender disclosed IO payments in all 4 columns, not disclosing end of IO period into account as required under Reg Z.

Reviewer Comment (2016-11-07): Qualification method corrected.  ATR is met.

11/07/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996864

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Reviewer Comment (2016-11-07): Qualification method corrected.  ATR is met.

11/07/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

200996864

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.74990% or Final Disclosure APR of 5.83100% is in excess of allowable threshold of APOR 3.20% + 2.5%, or 5.70000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Final Closing Disclosure does not reflect NMLS ID for lender contact.

Reviewer Comment (2016-11-04): Lender contact is a CS Rep and doesn't have a unique identifier.

11/04/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/89962)

Escrow payment does not match actual payment for the loan. Lender qualified using a lower tax amount.  Title commitment reflects a higher amount.

Reviewer Comment (2016-12-23): Data correct on subsequent CDs (SFIG).

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/89963)

Escrow payment does not match actual payment for the loan. Lender qualified using a lower tax amount.  Title commitment reflects a higher amount.

Reviewer Comment (2016-12-23): Data correct on subsequent CDs (SFIG).

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/89964)

Escrow payment does not match actual payment for the loan. Lender qualified using a lower tax amount.  Title commitment reflects a higher amount.

Reviewer Comment (2016-12-23): Data correct on subsequent CDs (SFIG).

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/89965)

Escrow payment does not match actual payment for the loan. Lender qualified using a lower tax amount.  Title commitment reflects a higher amount.

Reviewer Comment (2016-12-23): Data correct on subsequent CDs (SFIG).

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/89962)

Escrow payment does not match actual payment for the loan. Lender qualified using a lower tax amount.  Title commitment reflects a higher amount.

Reviewer Comment (2016-12-23): Data correct on subsequent CDs (SFIG).

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Interest Only Until

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [MM/DD/YYYY] with an increasing payment disclosed the due date of the last payment of interest only that does not match the actual last payment for the loan. (Final/[MM/DD/YYYY])

Final closing Disclosure reflect the interest only period as the term of the loan.  Should only be 120 payments or 10 years.

Reviewer Comment (2016-11-10): Per Compliance, this is acceptable.  No violation.

11/10/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-09): Valid Change of Circumstance received.  No violation.

11/09/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Revised Loan Estimate provided on [MM/DD/YYYY].  Initial Closing Disclosure dated [MM/DD/YYYY].

Reviewer Comment (2016-11-04): Received evidence that borrower received disclosure within timing requirements.

11/04/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Cure for Loan Discount Points and Loan Origination fees of $517.50 was not provided.

Reviewer Comment (2016-11-09): Valid Change of Circumstance received.  No violation.

11/09/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $1,817.50 exceeds tolerance of $1,795.00. (7200)

Loan Discount Points Fee disclosed as $1,795.00 on LE dated [MM/DD/YYYY], but disclosed as $1,817.50 on Final Closing Disclosure.

Reviewer Comment (2016-11-09): Valid Change of Circumstance received.  No violation.

11/09/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Origination Fee.  Fee Amount of $39,985.00 exceeds tolerance of $39,490.00. (7325)

Loan Origination Fee disclosed as $39,490.00 on LE dated [MM/DD/YYYY], but disclosed as $39,985.00 on Final Closing Disclosure.

Reviewer Comment (2016-11-09): Valid Change of Circumstance received.  No violation.

11/09/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Loan estimate dated [MM/DD/YYYY] was issued without Cash From/To Borrower present.

Reviewer Comment (2016-11-09): This is allowed on Brokered Loans.

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TIP of 122.616% but calculated TIP is 120.292%, which is outside of .003% tolerance.  Used Index Value = 1.5562% per Loan Transmittal document in file.

Reviewer Comment (2016-11-07): Verified index used.  Recalculation reflects no TIP violation.

11/07/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

200996864

Credit

Loan Package Documentation

Closing / Title

Loan is Interest Only and the Interest Only Rider is missing

Reviewer Comment (2016-11-10): Part of ARM Rider.

11/10/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996864

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Closing Disclosure dated [MM/DD/YYYY] did not reflect payee for the Appraisal.

Reviewer Comment (2016-11-09): Data correct on subsequent CDs.

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996864

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Closing disclosure dated [MM/DD/YYYY] reflects Title-Title Endorsement fee in section C Services Borrower Did Shop For. It should have been in Section B since service provider is listed on the SSPL.

Reviewer Comment (2016-11-10): Data correct on subsequent CDs.

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996864

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Appears borrower total debt was not included in calculations.

Borrower on this full documentation loan has a disposable income of $16,641. 78% LTV < 90 guideline max

Reviewer Comment (2016-11-09): Client elects to waive.

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

Non QM

Non QM

No

C

B

200996867

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996867

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.84100% or Final Disclosure APR of 8.72600% is in excess of allowable threshold of APOR 3.15% + 1.5%, or 4.65000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996867

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

200996867

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2016-11-16): File moved to Non-QM designation.

11/16/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996867

Compliance

Compliance

Federal Compliance

QM Points and Fees

Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of 3.93004% is in excess of the allowable maximum of  3.00000% of the Federal Total Loan Amount. Points and Fees total $6,331.50 on a Federal Total Loan Amount of $161,105.34 vs. an allowable total of $4,833.16 (an overage of $1,498.34 or .93004%).

Reviewer Comment (2016-11-16): File switched to Non-QM.

11/16/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

If a creditor or assignee determines after consummation that the total points and fees exceeds the 3% limit, but the loan meets the other requirements to be a QM, the excess amount can be refunded with the following conditions: 1) The refund is made within 210 days of consummation; 2) The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit; 3) The loan is not 60 days delinquent; 4) The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments). The lender will also be required to provide a copy of the refund check and proof of delivery.

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

200996867

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects Finance Charges of ($284,797.91) however calculated Finance Charges reflects ($292,773.10).

Reviewer Comment (2016-11-25): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/25/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996867

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TIP of (165.056%) but calculated TIP is (169.791%).  Used Index Value = (1.557%) per (Loan Transmittal Form) document in file.

Reviewer Comment (2016-12-02): Data correct on subsequent CDs (SFIG).

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

200996867

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total of Payments that does not match the actual total of payments for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TOP of ($454,211.54) but calculated TOP of ($462,186.73).  Variance = ($7975.19).  Used Index Value = (1.557%) per (Loan Transmittal Form) document in file.

Reviewer Comment (2016-12-02): Data correct on subsequent CDs (SFIG).

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996867

Compliance

Compliance

Federal Compliance

ARM Disclosure Status

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.

Reviewer Comment (2016-12-02): Received evidence that borrower received disclosure within timing requirements.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996867

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2016-12-02): Received evidence that borrower received disclosure within timing requirements.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

200996867

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on[MM/DD/YYYY], prior to three (3) business days from transaction date of[MM/DD/YYYY].

Disbursement date of [MM/DD/YYYY] reflected on Final CD is prior to Right to Cancel Expiration date of [MM/DD/YYYY].

Reviewer Comment (2016-11-01): Data was corrected on post close CD (SFIG).

11/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

200996867

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

31 months reserves > 3 months guideline minimum

Reviewer Comment (2016-11-03): Client elects to waive.

11/03/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201001353

Credit

Assets

Asset Documentation

Missing Document: Gift Letter not provided

The borrower's bank statement reflects a deposit of $ on that came from a withdrawal from the non-borrowing spouse's account. Gift letter is required.

Reviewer Comment (2016-11-11): Received copy of gift letter.

11/11/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201001353

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

The Seller's CD reflects seller paid closing costs of $67,222.15 and the borrower's CD reflects $3,984.40.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201001353

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

TILA-RESPA Integrated Disclosure: Settlement Service Provider List did not provide at least one available provider for each settlement service borrower is entitled to shop for or inform borrower they may choose different provider from list.

The SSPL does not list services the borrower can shop for.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201001353

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-12-07): Received evidence that borrower received disclosure within timing requirements.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201001353

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2016-12-07): Received evidence that borrower received disclosure within timing requirements.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201006865

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.92290% or Final Disclosure APR of 6.97700% is in excess of allowable threshold of APOR 3.17% + 2.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201006865

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.92290% or Final Disclosure APR of 6.97700% is in excess of allowable threshold of APOR 3.17% + 2.5%, or 5.67000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201006865

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Data correct on subsequent CDs (SFIG). Buyer Comment (2016-12-01): Please disregard uploaded in error.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201006865

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Data correct on subsequent CDs (SFIG).

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201006865

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-5.00. (9300)

Reviewer Comment (2016-12-07): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2016-12-02): Received copy of corrected CD.  Missing copy of check and proof of delivery. Reviewer Comment (2016-11-07): The first CD from 10/4 reflects a cure of $940.50 and a credit for $945.50, while the final CD reflects a cure of $945.50 and a credit for $945.50.  The $5 credit is not reflected on final CD.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201006865

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-12-12): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2016-11-14): Document provided does not have an issue date and is signed [MM/DD/YYYY].  Missing ARM disclosure issued with original application package.

12/12/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201006865

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-12): Unable to locate upload or comment addressing this exception. Buyer Comment (2016-12-01): Disregard second upload "[MM/DD/YYYY]" was done in error.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201006866

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.89050% or Final Disclosure APR of 6.89100% is in excess of allowable threshold of APOR 3.18% + 2.5%, or 5.68000%.  Compliant Higher Priced Mortgage Loan.

HPML per tape data.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201006866

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.89050% or Final Disclosure APR of 6.89100% is in excess of allowable threshold of APOR 3.18% + 2.5%, or 5.68000%.  Compliant Higher Priced Loan.

HPML per tape data.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201006866

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's Closing Disclosure reflects total seller paid fees as $47,908.86 and Consumer's Final Closing Disclosure reflects them as $39,562.20.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201006866

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

1.43 months reserves is less than 9 months required by lender. Lender exception was provided, however the residual income used is no longer a viable comp factor as increase in taxes reduced the required residual income below requirements.  Lender to address.

Borrower on this loan has a disposable income of $6,500.

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201006866

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

51.841% DTI exceeds maximum 50% DTI. Lender used $611.58 monthly taxes on 1003, 1008 and AUS. Review used $913.54 supported by the final CD and tax cert provided.

Reviewer Comment (2016-12-28): Lender has grossed up child support.  DTI now within guidelines.

12/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201006866

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Shopped for title fees are identified in section B, these should be listed in section C.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201006866

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Disposable income discrepancy.

Required residual income of $6350 not met.

Reviewer Comment (2016-12-28): Lender has grossed up child support.  Residual Income now within guidelines.

12/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201009454

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.39970% or Final Disclosure APR of 7.40200% is in excess of allowable threshold of APOR 3.53% + 2.5%, or 6.03000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.  The loan is designated as a higher priced loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201009454

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 7.39970% or Final Disclosure APR of 7.40200% is in excess of allowable threshold of APOR 3.53% + 2.5%, or 6.03000%.

All fees have been verified as entered from the final CD.  The loan is designated as a higher priced loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201009454

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-11): Received evidence that borrower received disclosure within timing requirements.

11/11/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201009454

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-23): Received evidence that borrower received disclosure within timing requirements.

11/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201009454

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The Sellers CD has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201009459

Credit

Credit

Misc

Credit Exception:

Final 1003 does not list the Borrower's job title/position.

Reviewer Comment (2016-12-07): Received corrected 1003 listing occupation.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201009459

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201009459

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-14): Received evidence that borrower received disclosure within timing requirements.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201009459

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Final Closing Disclosure does not reflect NMLS ID for lender contact.

Reviewer Comment (2016-11-14): Lender contact is a CS Rep and doesn't have a unique identifier.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201009459

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-11-14): Received evidence that borrower received disclosure within timing requirements.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201009459

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201009459

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Appraisal reflects estimated cost new of $. Insurance coverage is $. Coverage shortfall of $7,759.00.

Reviewer Comment (2016-11-25): Received evidence that coverage is max allowed by insurer.

11/25/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201009459

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201009459

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00. (7580)

Tax Service Fee disclosed as $90.00 on LE dated [MM/DD/YYYY], but disclosed as $92.00 on Final Closing Disclosure.

Reviewer Comment (2016-11-14): Cured at closing.

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201009459

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Closing Disclosure dated [MM/DD/YYYY] does not reflect payee in Section C for Hazard inspection fee, Pest inspection fee and Structural/Other Inspection fee.

Reviewer Comment (2016-11-14): Data correct on subsequent CDs (SFIG).

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201009459

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

LE dated [MM/DD/YYYY] reflects fees in section H as Additional Charges.

Reviewer Comment (2016-11-14): Data correct on subsequent CDs (SFIG).

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201009459

Credit

Credit

Misc

Credit Exception:

Guidelines require a Collateral Desktop Analysis.  CDA was not provided.

Borrower has employment stability for 20 years in the [REDACTED] Industry. Borrowers made a down payment of $125,731.50 from their own funds on this purchase transaction.

Reviewer Comment (2016-11-08): Client elects to waive.

11/08/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201009461

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.71840% or Final Disclosure APR of 7.72600% is in excess of allowable threshold of APOR 3.49% + 1.5%, or 4.99000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201009461

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201009461

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $4,927.50 exceeds tolerance of $4,654.00. (7200)

Fee disclosed as ($4654.00) on (LE or CD dated [MM/DD/YYYY]), but disclosed as ($4927.50) on Final Closing Disclosure.

Reviewer Comment (2016-11-08): Cure provided on Final CD.

11/08/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201009461

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Missing secondary valuation as required by guidelines.

38% DTI on this full documentation loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2016-11-08): Client elects to waive.

11/08/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201009462

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

The hazard insurance only covers $ Which is not greater than the loan amount or the estimated cost new.

Reviewer Comment (2016-11-23): Re-review of coverage shows it is sufficient.

11/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201009462

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.81820% or Final Disclosure APR of 5.81800% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201009462

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.81820% or Final Disclosure APR of 5.81800% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201009462

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-10): Received evidence that borrower received disclosure within timing requirements.

11/10/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201009462

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201009462

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

Per diem interest is $117.44.  $117.44 * 4 days = $469.76 however disclosure reflects $496.12.

Reviewer Comment (2016-11-08): Data correct on subsequent CDs.

11/08/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201011498

Credit

Credit

Credit Eligibility

There are red flags on the fraud report that have not been addressed

Report is Auto-refer

Reviewer Comment (2016-11-29): Client attests that documentation provided appropriately address the concerns flagged by Fraud Guard.

11/29/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

C

B

201011498

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - K-1 Less 25%

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current K-1 (Less than 25% Ownership) status using reasonably reliable third-party records.

Missing 3rd Party verification and VVOE.

Reviewer Comment (2016-11-28): Received all required income documentation.

11/28/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

C

B

201011498

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - K-1 Less 25%

Ability to Repay (Dodd-Frank 2014): Unable to verify K-1 (Less than 25% Ownership) income using reasonably reliable third-party records.

Missing 3rd Party verification and VVOE.

Reviewer Comment (2016-11-28): Received all required income documentation.

11/28/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

C

B

201011498

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - S-Corp

Ability to Repay (Dodd-Frank 2014): Unable to verify S-Corp income using reasonably reliable third-party records. ([REDACTED])

Missing 3rd Party verification and VVOE.

Reviewer Comment (2016-11-28): Received all required income documentation.

11/28/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

C

B

201011498

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Missing 3rd Party verification and VVOE.

Reviewer Comment (2016-11-28): Received all required income documentation.

11/28/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

N/A

No

C

B

201011498

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

Reviewer Comment (2016-11-21): File is irregular transaction and APR change is within tolerance. Reviewer Comment (2016-11-15): The canned exception appears to be poorly worded and doesn't reflect the actual issue.  There is a CD issued 9/20 that reflects an APR of 6.875.  The final CD reflects 7.105%.  The final CD is > .125% from previous CD issued 9/20.

11/21/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

C

B

201011498

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $450.00. (7506)

Reviewer Comment (2016-11-14): Cured at closing.

11/14/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

Yes

C

B

201011498

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2016-11-18): Updated asset statement found in file.  Asset requirement met.

11/18/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

C

B

201011501

Credit

Assets

Asset Documentation

Assets Error: Usability  was not provided

Assets are business assets in the amount of . A cash flow analysis or a letter from the business accountant is required to confirm that the withdrawal will not negatively impact the business was not provided.

Reviewer Comment (2016-11-14): Received  copy of cash flow analysis.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201011501

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Secondary desk review valuation not provided.

665 representative FICO score > 620 guideline minimum - 45 points above guideline minimum

Reviewer Comment (2016-11-09): Client elects to waive.

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201011501

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $150.00 exceeds tolerance of $.00. (7505)

Reviewer Comment (2016-11-09): Cured on final CD

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201011501

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $91.00. (7580)

Reviewer Comment (2016-11-09): Cured on final CD

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201011501

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201011501

Compliance

Compliance

Federal Compliance

RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure

RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201011501

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender contact NMLS number was not provided.

Reviewer Comment (2016-12-06): Lender contact is a CS Rep and doesn't have a unique identifier.

12/06/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201011501

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

Seller's Disclosure was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201011501

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-11): Received evidence that borrower received disclosure within timing requirements.

11/11/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201012455

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal was made "subject to" and Form 442 was not provided.

Valuation Type: Appraisal / Valuation Report Date: <empty>

Lender granted 6 months for completion for garage to be converted back to garage.

Borrower on this full documentation loan has a disposable income of $3,991 above guidelines requirement of $5,900 Borrower has 24 months of reserves, guideline requirement is 3.

Reviewer Comment (2016-12-21): Client accepts attestation that 442 will be provided upon completion of garage in 3/17.

12/21/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201012455

Compliance

Compliance

State Compliance

(State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided)

Maryland Higher-Priced Mortgage Loan:  Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for.

Reviewer Comment (2016-11-14): Received evidence that borrower received disclosure within timing requirements.

11/14/2016

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201012455

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 7.01990% or Final Disclosure APR of 7.02100% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201012455

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $.00. (75106)

Collateral Desktop Analysis fee was not disclosed on Loan Estimate.

Reviewer Comment (2016-11-14): Cured at closing.

11/14/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201012455

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Loan Estimate dated [MM/DD/YYYY] reflects fees in Section H as Additional Charges. Fees are not named and itemized.

Reviewer Comment (2016-11-14): Data correct on subsequent CDs (SFIG).

11/14/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201012455

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Closing Disclosure dates [MM/DD/YYYY] does not identify payees for Title fees.

Reviewer Comment (2016-11-10): Data correct on subsequent CDs.

11/10/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201012455

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Final Closing Disclosure reflects Title-Lender Title Insurance in section B and all other Title services are disclosed in Section C. Title -Lender Title Insurance fee should have been disclosed in Section C. Service Provider is not listed on the SSPL as a service the borrower can shop for. The Service provider is an affiliate of the seller.

Reviewer Comment (2016-11-23): Data correct on subsequent CDs (SFIG).

11/23/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201012455

Credit

Credit

Misc

Credit Exception:

Rate lock information was not provided.

Reviewer Comment (2016-12-02): Received copy of Rate Lock.

12/02/2016

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201012455

Credit

Credit

Misc

Credit Exception:

Lender Approved exception to allow 180 days leaseback of the subject property approved as a second home. Property to be leased to the builder after closing for a short period.  Purchased as a second home.

Borrower on this full documentation loan has a disposable income of $3,991 above guidelines requirement of $5,900 Borrower has 24 months of reserves, guideline requirement is 3.

Reviewer Comment (2016-11-10): Client elects to wave.

11/10/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201012455

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Interim/[MM/DD/YYYY])

E-consent disclosure signed on [MM/DD/YYYY]. Loan Estimate  dated [MM/DD/YYYY] was e-signed on [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201012455

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure reflects fees paid of $16,856.85. The Final Closing Disclosure  reflects seller paid fees of $16,000.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201012456

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.01470% or Final Disclosure APR of 7.01500% is in excess of allowable threshold of APOR 3.17% + 2.5%, or 5.67000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201012456

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2016-11-14): Received replacement cost estimator from insurance.  Coverage is maxed out.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201012456

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201012456

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201012456

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Borrower on this Full documentation loan has a disposable income of $17273.45 26 months reserves > 9 months guideline minimum

Reviewer Comment (2016-11-09): Client elects to waive.

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201012456

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2016-11-21): Recalculation of assets show enough liquid for closing. Reviewer Comment (2016-11-14): Actual to Cash from Borrower should be $84,647.32.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201012462

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Final CD is missing Lender contact NMLS ID.

Reviewer Comment (2016-11-14): Lender contact is a CS Rep and doesn't have a unique identifier.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201012462

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Missing secondary valuation.

7 months reserves > 3 months guideline minimum

Reviewer Comment (2016-11-10): Client elects to waive.

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201012462

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

1003 Error: Citizenship Source Documentation  was not provided

Borrower:

Initial and final 1003 indicate borrower is non-US citizen, not a permanent resident alien.  Citizenship documentation has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201012462

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant.  Seller paid fees on Sellers Closing Disclosure are not consistent with those reflected on the Borrowers Final Closing Disclosure.  Sellers CD reflects $19,874.88 in seller paid fees.  Combined CD disclosed $24,699 seller paid fees.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201012494

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-14): Received evidence that borrower received disclosure within timing requirements.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201012494

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201012494

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Final Closing disclosure reflects seller paid fees of $40,668.00. Fees from the Seller Closing Disclosure are $46,616.19.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201012494

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $874.00 exceeds tolerance of $119.00 plus 10% or $130.90 (0)

Cure for 10% tolerance violation ($874.00) was not provided.

Reviewer Comment (2016-11-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201012494

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Cure of $0.60 was reflected, which is insufficient to cure  Title-Examination Fee of $775.00.

Reviewer Comment (2016-11-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201012494

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Borrowers used the vendor on SSPL, however, the Title-Title Examination fees were listed on section C instead of section B of Closing Disclosure.  Note:  SSPL shows title as [REDACTED] and CD shows [REDACTED] and Title in file is from [REDACTED] Title, issued by [REDACTED].

Reviewer Comment (2016-11-14): Data correct on subsequent CDs (SFIG).

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201012494

Credit

Credit

Misc

Credit Exception:

Lender approved exception to allow domestic partner used for rent free housing to not occupy the subject property as required by guidelines. Guidelines do not require that the relative be an occupant of the subject property. Guidelines require a letter from the relative confirming there is/was not monthly obligation. Documentation provided that the relative provided $ to the borrower for release and discharge to claims to the departure residence.

25.649% DTI on this Full documentation loan < 50% guideline maximum Borrower on this Full documentation loan has a disposable income of $8,095.90.

Reviewer Comment (2016-11-09): Client elects to waive.

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201012494

Credit

Credit

Misc

Credit Exception:

Missing Secondary Valuation.

25.649% DTI on this Full documentation loan < 50% guideline maximum Borrower on this Full documentation loan has a disposable income of $8,095.90.

Reviewer Comment (2016-11-09): Client elects to waive.

11/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201027422

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on [MM/DD/YYYY] reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section. (Final/[MM/DD/YYYY])

Section B reflects paid to broker/lender; payee must reflect the actual vendor in some manor (FBO, reimbursement to, etc).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201027422

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $10,031.77, while closing CD seller's fees total $3285.10.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201027422

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $2,950.08 exceeds tolerance of $2,949.00. (8304)

Fee disclosed as ($2949.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($2950.08) on Final Closing Disclosure.

Reviewer Comment (2016-11-25): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/25/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201027422

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Missing secondary valuation as required by guidelines.

19 months reserves > 3 months guideline minimum

Reviewer Comment (2016-11-10): Client elects to waive.

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201027422

Compliance

Compliance

Federal Compliance

TRID non-compliant:  There is a partially completed TRID disclosure in file, which is insufficient to complete testing.

Reviewer Comment (2016-11-16): Received attestation that disclosure was produced by title and never presented to borrower.

11/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201027422

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure of ($0.45) was reflected, which is insufficient to cure ($1.08)

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201027422

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Cure of ($0.45) was reflected, which is insufficient to cure ($1.08)

Reviewer Comment (2016-11-25): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/25/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201039202

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $.00. (75106)

Reviewer Comment (2016-11-14): Cured at closing.

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201039202

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-14): Sufficient cure provided.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201039202

Credit

Loan Package Documentation

Application / Processing

Missing Document: Other not provided

Missing secondary valuation.  Fee charged but no review provided.

28% DTI on this full documentation loan < 50% guideline max - 22% below program guideline maximum

Reviewer Comment (2016-11-14): Client elects to waive.

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201039203

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-15): Received evidence that borrower received disclosure within timing requirements.

11/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201039203

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201039203

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception.

Residual Income required: $1650.00; Verified: $6805.30; Excess of $5155.30 Primary Borrower also receives OT, On-call and Incentive pay - UW did not use any of this income to qualify. Max DTI is 50%; Actual DTI is 27.91212%

Reviewer Comment (2016-11-10): Client elects to waive.

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201039203

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Residual Income required: $1650.00; Verified: $6805.30; Excess of $5155.30 Primary Borrower also receives OT, On-call and Incentive pay - UW did not use any of this income to qualify. Max DTI is 50%; Actual DTI is 27.91212%

Reviewer Comment (2016-11-10): Client elects to waive.

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201039204

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.82320% or Final Disclosure APR of 5.82300% is in excess of allowable threshold of APOR 3.18% + 2.5%, or 5.68000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2016-11-17): Exception erroneously set as EV3.  Reset at EV2.

11/17/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039204

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-16): Received evidence that borrower received disclosure within timing requirements.

11/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039204

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-29): Data correct on subsequent CDs (SFIG).

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201039204

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.82320% or Final Disclosure APR of 5.82300% is in excess of allowable threshold of APOR 3.18% + 2.5%, or 5.68000%.  Compliant Higher Priced Mortgage Loan.

Original exception erroneously set as EV3.  Reset at EV2.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201039205

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.71790% or Final Disclosure APR of 6.71900% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201039205

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $988.00 exceeds tolerance of $866.00 plus 10% or $952.60 (0)

Reviewer Comment (2016-11-11): Cured on closing CD.

11/11/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039205

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

64 months reserves > 6 months guideline minimum

Reviewer Comment (2016-11-14): Client elects to waive.

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

No

C

B

201039205

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-13): Designation switched to Rebuttable Presumption

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201039206

Compliance

Compliance

Federal Compliance

Retirement Documentation

Qualified Mortgage (Dodd-Frank 2014): Retirement income documentation insufficient.

Provide documentation to show that the pension payment from  will continue for at least three years.

Reviewer Comment (2016-11-21): File switched to Non-QM

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039206

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2016-11-21): File switched to Non-QM

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201039206

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Missing Secondary valuation.

29 months reserves > 9 months guideline minimum

Reviewer Comment (2016-11-10): Client elects to waive.

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201039206

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant - CD in file (Pg 410) shows mostly incomplete information, and is not labeled as a "Draft", "Title Copy Only", or other such designation to indicate it was not provided to borrower.

Reviewer Comment (2016-11-15): Received attestation that disclosure was produced by title and never presented to borrower.

11/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201039206

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Lender approved DTI did not included expenses for departure residence

Reviewer Comment (2016-11-21): File switched to Non-QM

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039206

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on 1[MM/DD/YYYY] reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section. (Final/[MM/DD/YYYY])

Final Closing Disclosure reflects the Collateral Desktop Analysis fee as paid to the Lender.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201039206

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller disclosure reflects seller paid fees of $15,798.14. Final Closing Disclosure reflects seller paid fees of $14,507.73.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201039206

Credit

Credit

Misc

Credit Exception:

Provide documentation of taxes and insurance on departure residence.

Reviewer Comment (2016-11-21): Received required verification. Reviewer Comment (2016-11-21): Unable to locate document associated with this exception.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039206

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

29 months reserves > 9 months guideline minimum Borrower on this full documentation loan has a disposable income of $2310

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201039207

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.00540% or Final Disclosure APR of 6.00500% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201039207

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.00540% or Final Disclosure APR of 6.00500% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201039207

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-16): Received evidence that borrower received disclosure within timing requirements.

11/16/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039207

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender exception on file.  Compensating factors captured.

Guideline variance approved by lender at time of origination.  DTI of 56.5%.  Guideline maximum 50%. 20 months of reserves available.  3 months required by guidelines. Demonstrated and verified consistent on-time primary housing payment history for 44 months, which is 20 months beyond guideline requirement of 24 months. Excess residual income of $3557.12, exceeding the $2800 requirement

Reviewer Comment (2016-11-15): Client elects to waive.

11/15/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201039207

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Final Closing Disclosure does not reflect a payee for Title-Document Preparation Fee.

Reviewer Comment (2016-11-17): Data correct on subsequent CDs (SFIG). Reviewer Comment (2016-11-16): Unable to locate document associated with the exception.  Appears upload error.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201039207

Credit

Credit

Misc

Credit Exception:

Guidelines require most recent two months' statements or most recent quarterly statement. Only one month's statement provided.

Reviewer Comment (2016-11-17): Received VOD allowed per guidelines.

11/17/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039208

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-14): Received evidence that borrower received disclosure within timing requirements.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039208

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Closing Disclosure dated [MM/DD/YYYY], [MM/DD/YYYY] does not reflect Lender Contact's NMLS ID.

Reviewer Comment (2016-11-14): Lender contact is a CS Rep and doesn't have a unique identifier.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201039208

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201039208

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $775.00 exceeds tolerance of $650.00. (7506)

Appraisal Fee disclosed as $650.00 on LE dated [MM/DD/YYYY], but disclosed as $775.00 on Final Closing Disclosure.

Reviewer Comment (2016-11-14): Cured at closing.

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201039208

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Closing Disclosure dated [MM/DD/YYYY] does not identify payee for the Appraisal Fee, Appraisal Field Review Fee, Pest Inspection and Title-Notary Fees, Home Inspection And Home Warranty Fee.

Reviewer Comment (2016-11-14): Data correct on subsequent CDs (SFIG).

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201039208

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201039208

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

CDA in file reflects Indeterminate Value.

Reviewer Comment (2016-11-14): The Field review provided, supports the OA value.

11/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039209

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2016-11-15): Received evidence that HOI has extended replacement cost that covers required amount.

11/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039209

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201039209

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-15): Received evidence that borrower received disclosure within timing requirements.

11/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039209

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201039210

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Closing Disclosure provided [MM/DD/YYYY]. Closing was 1[MM/DD/YYYY]

Reviewer Comment (2016-11-16): Received evidence that borrower received disclosure within timing requirements.

11/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201039210

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201039210

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

There is no secondary valuation in file.

14 months > 9 required.

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201039210

Compliance

Compliance

Federal Compliance

TRID - the file contains an illegible TRID disclosure. Testing is incomplete

provide closing disclosures that do not provide all pages or are incomplete.

Reviewer Comment (2016-11-21): Received attestation that disclosure was produced by title and never presented to borrower.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

A

D

A

D

A

D

A

D

A

Non QM

Non QM

Yes

D

B

201039210

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.37920% or Final Disclosure APR of 7.37900% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

D

B

201039212

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-15): Received evidence that borrower received disclosure within timing requirements.

11/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039212

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201039212

Credit

Credit

Misc

Credit Exception:

Guideline requires Self-Employed borrowers to have 2 year history of employment and income.  Borrower owns that borrower purchased in the name of an LLC  \.  Lender used current lease with 25% vacancy factor without a 2 year history of income receipt.  Lender approved exception.

Significant residual income of $7,366.40 which exceeds required of $3,050 Maximum LTV is 90%, subject LTV 80%

Reviewer Comment (2016-11-15): Client elects to waive.

11/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201039213

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-15): Received evidence that borrower received disclosure within timing requirements.

11/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039213

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-12-06): Received evidence that borrower received disclosure within timing requirements.

12/06/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201039213

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception.

Borrower on this full documentation loan has a disposable income of $3,180.90.  $1,380.91 in excess of required $1,800. 32.608% DTI on this full documentation loan < 50% guideline max - 17% below program guideline maximum

Reviewer Comment (2016-11-10): Client elects to waive.

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201039213

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Borrower on this full documentation loan has a disposable income of $3,180.90.  $1,380.91 in excess of required $1,800. 32.608% DTI on this full documentation loan < 50% guideline max - 17% below program guideline maximum

Reviewer Comment (2016-11-10): Client elects to waive.

11/10/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201039214

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.14580% or Final Disclosure APR of 8.14600% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201039214

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD closing date is [MM/DD/YYYY], actual closing date is [MM/DD/YYYY] per notary date.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201039214

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for HOA/Condo Questionnaire.  Fee Amount of $275.00 exceeds tolerance of $225.00. (75215)

Reviewer Comment (2016-11-14): Cured on closing CD

11/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201039214

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201039214

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Missing secondary valuation.

705 representative FICO score > 660 guideline minimum - 45 points above guideline minimum

Reviewer Comment (2016-11-15): Client elects to waive.

11/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201039375

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.01490% or Final Disclosure APR of 7.04800% is in excess of allowable threshold of APOR 3.49% + 2.5%, or 5.99000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201039375

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/95579)

Payment is off by $674.57

Reviewer Comment (2016-11-30): Data correct on subsequent CDs (SFIG).

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039375

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/95579)

Estimated Escrow Payment is off by $674.57

Reviewer Comment (2016-11-30): Data correct on subsequent CDs (SFIG).

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039375

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow -  Monthly Escrow Payment

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed the Monthly Escrow Payment that does not match the actual escrow payment for the loan. (Final/[MM/DD/YYYY])

Payment is off by $674.57

Reviewer Comment (2016-11-30): Data correct on subsequent CDs (SFIG).

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039375

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Payment Min Payment Fixed Rate Initial Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/95579)

Reviewer Comment (2016-11-30): Data correct on subsequent CDs (SFIG).

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039375

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

No

C

B

201039375

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-13): Designation switched to Rebuttable Presumption.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

No

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-12): Received evidence that borrower received disclosure within timing requirements.

12/12/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AIR Table Maximum Interest Rate

TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Maximum Interest Rate that does not match the actual maximum interest rate for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-17): Revised Closing disclosure dated [MM/DD/YYYY].

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Interest Rate that does not match the actual interest rate for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-17): Revised post closing,  Closing Disclosure issued on [MM/DD/YYYY].

11/17/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate Max Rate

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on[MM/DD/YYYY] with an increasing interest rate disclosed a maximum interest rate that does not match the actual maximum rate for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a negative fee amount. (Final/[MM/DD/YYYY])

Final Closing Disclosure reflects -125.00 in Section H Other for Technology Fee.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Max Amount

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on[MM/DD/YYYY] with an increasing payment disclosed the maximum possible amount of principal and interest that does not match the actual maximum amount for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Principal and Interest

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Principal and Interest Payment that does not match the actual payment for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/96265)

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/96266)

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/96267)

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 2 that does not match the actual maximum payment for the loan. (ProjSeq:2/96265)

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 3 that does not match the actual maximum payment for the loan. (ProjSeq:3/96266)

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 4 that does not match the actual maximum payment for the loan. (ProjSeq:4/96267)

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Min Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/96264)

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Lender used an index value that was outside the lookback period per the Note.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Final Closing disclosure reflects seller paid fees of $9,534.00. Seller Closing Disclosure closing costs paid are $8,760.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Secondary Valuation not provided.

38% DTI on this loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

No

C

B

201039376

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2017-01-05): Received attestation that red flags have been addressed sufficiently. Reviewer Comment (2016-12-16): Received same report that was uploaded on 12/8.  Red Flags noted in last comment still have not been addressed. Reviewer Comment (2016-12-08): Fraud report received.  however, borrower is in Critical Risk.  Red Flags must be addressed.

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201039376

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/96264)

Reviewer Comment (2016-11-17): Post closing CD issued on [MM/DD/YYYY] to correct information.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201039376

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.60520% or Final Disclosure APR of 8.90400% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201039376

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-13): Designation switched to Rebuttable Presumption.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201049752

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.55180% or Final Disclosure APR of 6.55300% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201049752

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-18): Lender contact is a CS Rep and doesn't have a unique identifier.

11/18/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201049752

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-17): Cured at closing.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201049752

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201049752

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Reviewer Comment (2016-11-17): Cured at closing.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201049752

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $850.00. (7506)

Reviewer Comment (2016-11-17): Cured at closing.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201049752

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $35.00 exceeds tolerance of $29.00. (7520)

Valid exception

Reviewer Comment (2016-11-17): Cured at closing.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201049752

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00. (7580)

Valid exception

Reviewer Comment (2016-11-17): Cured at closing.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201049753

Credit

Credit

Misc

Credit Exception:

Rental income derived from the subject property cannot be used on purchase transactions; Lender approved exception with compensating factors was provided.

Residual income in excess of current guideline requirements- $800 required, $2907.69 actual, excess of $2107.69 per month (without considering rental income for subject). Verified cash reserves in excess of the 9 months required with an additional 3 month subject PITIA. DTI ratio significantly below 43% at 32.26%.

Reviewer Comment (2016-11-17): Client elects to waive.

11/17/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201049753

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201049754

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-18): Received evidence that borrower received disclosure within timing requirements.

11/18/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201049754

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID missing

Reviewer Comment (2016-11-18): Lender contact is a CS Rep and doesn't have a unique identifier.

11/18/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201049754

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Application date was[MM/DD/YYYY], missing initial LE dated[MM/DD/YYYY] although there is an intent to proceed signed by borrower 9/21 acknowledging receipt of LE.

Reviewer Comment (2016-11-18): Received evidence that borrower received disclosure within timing requirements.

11/18/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201049754

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Closing CD fees paid by seller was $12,509.08, Seller's CD seller's fees were $21,285.55.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201049754

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Application date[MM/DD/YYYY], ARM disclosure dated [MM/DD/YYYY].

Reviewer Comment (2016-11-25): Received evidence that borrower received disclosure within timing requirements.

11/25/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201049755

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-21): Received evidence that borrower received disclosure within timing requirements.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201049755

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Final CD did not provide lender contact NMLS ID.

Reviewer Comment (2016-11-21): Lender contact is a CS Rep and doesn't have a unique identifier.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201049755

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant.  Seller paid fees on Sellers Closing Disclosure are not consistent with those reflected on the Borrowers Final Closing Disclosure.  Sellers CD reflects $71,036.44 in seller paid fees.  Combined CD disclosed $4,459.00 in seller paid fees.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201049755

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.07670% or Final Disclosure APR of 7.07900% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201054903

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.68190% or Final Disclosure APR of 6.68200% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201054903

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201054903

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $850.00 exceeds tolerance of $550.00. (7506)

Reviewer Comment (2016-11-17): Cured on closing CD

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201054903

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Borrowers made a down payment of $4,000 from their own funds on this purchase transaction. Borrower has job stability for 5 years as an [REDACTED] Borrower on this 1008 documentation loan has a disposable income of $6,535.12

Reviewer Comment (2016-11-17): Client elects to waive.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201054904

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-12-06): Received attestation that disclosure was produced by title and never presented to borrower.

12/06/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201054904

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-21): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201054904

Credit

Credit

Misc

Credit Exception:

Secondary Valuation not provided.

12 months reserves > 3 months guideline minimum

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201054904

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant - CD in file  shows mostly incomplete information, and is not labeled as a "Draft", "Title Copy Only", or other such designation to indicate it was not provided to borrower.

Reviewer Comment (2016-11-17): Data was corrected on subsequent CDs.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201054905

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-21): Received evidence that borrower received disclosure within timing requirements.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201054905

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Missing Lender Contact 's  NMLS ID Number.

Reviewer Comment (2016-11-21): Lender contact is a CS Rep and doesn't have a unique identifier.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201054905

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201054905

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $145.17 exceeds tolerance of $75.00. (7520)

Reviewer Comment (2016-11-17): Final CD reflects 70.17 Lender Credit for tolerance cure.

11/17/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201054906

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-21): Received evidence that borrower received disclosure within timing requirements.

11/21/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

N/A

N/A

No

C

B

201054906

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201054906

Credit

Credit

Misc

Credit Exception:

Lender used YTD P&L with increasing income to be included in income calculation to offset lower prior year income.  Lender approved exception.

Residual income of $12,820.15 is above the minimum required of $5,050 for an excess of $7,770.15. 160 months reserves > 12 months guideline minimum. LTV of 70% is below the program maximum of 85%. Not using income of $1,800 per month from the subject property from [REDACTED]. There is a current 26 year lease in file reflecting it is transferable. 91 months perfect mortgage history on primary residence.

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201054906

Credit

Credit

Misc

Credit Exception:

Use of rental income on investment purchase.  Lender approved exception.

Residual income of $12,820.15 is above the minimum required of $5,050 for an excess of $7,770.15. 160 months reserves > 12 months guideline minimum. LTV of 70% is below the program maximum of 85%. Not using income of $1,800 per month from the subject property from [REDACTED]. There is a current 26 year lease in file reflecting it is transferable. 91 months perfect mortgage history on primary residence.

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201054906

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title agent reflected on SSPL and title fees reflected in section C versus B.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201054906

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

Residual income of $12,820.15 is above the minimum required of $5,050 for an excess of $7,770.15. 160 months reserves > 12 months guideline minimum. LTV of 70% is below the program maximum of 85%. Not using income of $1,800 per month from the subject property from [REDACTED]. There is a current 26 year lease in file reflecting it is transferable. 91 months perfect mortgage history on primary residence.

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201054907

Credit

Assets

Asset Documentation

Asset Issue:  Gift funds are missing evidence of receipt

Missing verification of source and receipt of  Gift Funds.

Reviewer Comment (2016-11-21): Received required documentation.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201054907

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Missing secondary valuation

38% DTI on this full documentation loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2016-11-18): Client elects tow waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201054907

Credit

Loan Package Documentation

Closing / Title

Missing Document: Rider - ARM not provided

Reviewer Comment (2016-11-21): Received copy of Rider.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201054907

Credit

Loan Package Documentation

Closing / Title

Missing Document: Rider - PUD not provided

Reviewer Comment (2016-11-21): Received copy of Rider.

11/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201054907

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD reflects $12,465.  Borrower's CD reflects $2,002.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201054907

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant:  Missing payee for Appraisal and Appraisal Re-Inspection fees.

Reviewer Comment (2016-11-21): Data correct on subsequent CDs (SFIG).

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058442

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Transaction Error: Outstanding liens were not paid at closing.

Date Issued: [MM/DD/YYYY]

Subject loan was approved as a Delayed financing without paying off 2nd lien used to purchase the property, and allowing the product to remain rate and term, and not as a cash out refinance.  Lender approved exception.

DTI of 36.599 is below 43% maximum Significant residual income of $8,631.88 over required of $2,800 LTV of 51.897% is significantly below program maximum of 85%

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Investment

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201058442

Credit

Credit

Credit Documentation

Aged document: Primary Valuation is older than guidelines permit

Valuation Type: Appraisal / Valuation Report Date: [MM/DD/YYYY]

Lender approved exception.

DTI of 36.599 is below 43% maximum Significant residual income of $8,631.88 over required of $2,800 LTV of 51.897% is significantly below program maximum of 85%

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Investment

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201058442

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Investment

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201058442

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Total cash-out discrepancy.

Lender approved exception.

DTI of 36.599 is below 43% maximum Significant residual income of $8,631.88 over required of $2,800 LTV of 51.897% is significantly below program maximum of 85%

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Investment

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201058442

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing copy of CDA.

DTI of 36.599 is below 43% maximum Significant residual income of $8,631.88 over required of $2,800 LTV of 51.897% is significantly below program maximum of 85%

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Investment

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201058443

Credit

Property - Appraisal

General Appraisal Requirements

Valuation Error: AVM value not provided.

Missing secondary valuation

11% DTI on this full documentation loan < 50% guideline max - 39% below program guideline maximum

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201058443

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact unique ID number missing

Reviewer Comment (2016-11-22): Lender contact is a CS Rep and doesn't have a unique identifier.

11/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058443

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058443

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058443

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $114.80 exceeds tolerance of $108.45. (7520)

Reviewer Comment (2016-11-18): Cured on closing CD

11/18/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058443

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2016-11-22): Received evidence that borrower received disclosure within timing requirements.

11/22/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201058444

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-22): Received evidence that borrower received disclosure within timing requirements.

11/22/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201058444

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 1[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-11-22): Received evidence that borrower received disclosure within timing requirements.

11/22/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201058444

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Final Closing disclosure reflects seller paid fees of $10,111.66.  Seller Closing Disclosure closing costs paid are $10,147.66.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201058444

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.68090% or Final Disclosure APR of 8.68100% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201058444

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,106.75 exceeds tolerance of $420.00 plus 10% or $462.00 (0)

Reviewer Comment (2016-11-18): Lender cured on the final CD with a sufficient tolerance cure.

11/18/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058444

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

28 months reserves > 3 months guideline minimum

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201058445

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-11-25): Lender contact is a CS Rep and doesn't have a unique identifier.

11/25/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058445

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for (Lender Credit) of ($1510.08) was not provided.

Reviewer Comment (2016-11-28): Received evidence that, per funding sheet from title, actual lender credit totaled $13,700.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201058445

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-12,189.92  is less than amount of binding Lender Credit previously disclosed in the amount of $-13,700.00. (9300)

Lender Credit disclosed as ($-13,700.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($-12,189.92) on Final Closing Disclosure.

Reviewer Comment (2016-11-28): Received evidence that, per funding sheet from title, actual lender credit totaled $13,700.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058445

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 1[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-25): Received evidence that borrower received disclosure within timing requirements.

11/25/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201058445

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $222,047.92, while closing CD seller's fees total $232,094.29.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201058445

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Lender approved exception.

Borrower on this (Full) documentation loan has a disposable income of $32,309.77 15.13 months reserves > 3 months guideline minimum - borrowers have verified reserves of $227,931.29 LTV of 80% is significantly below guidelines maximum of 90% Demonstrated and verified consistent on time housing payment history at current location, 12 month history above and beyond the 24 month requirement. Borrower has 36 months on current primary.

Reviewer Comment (2016-11-23): Client elects to waive.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201058445

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

Borrower on this (Full) documentation loan has a disposable income of $32,309.77 15.13 months reserves > 3 months guideline minimum - borrowers have verified reserves of $227,931.29 LTV of 80% is significantly below guidelines maximum of 90% Demonstrated and verified consistent on time housing payment history at current location, 12 month history above and beyond the 24 month requirement. Borrower has 36 months on current primary.

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201058445

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower on this (Full) documentation loan has a disposable income of $32,309.77 15.13 months reserves > 3 months guideline minimum - borrowers have verified reserves of $227,931.29 LTV of 80% is significantly below guidelines maximum of 90% Demonstrated and verified consistent on time housing payment history at current location, 12 month history above and beyond the 24 month requirement. Borrower has 36 months on current primary.

Reviewer Comment (2016-11-28): Client elects to waive. Reviewer Comment (2016-11-23): Incorrect exception waived. Reviewer Comment (2016-11-21): Client elects to waive.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201058446

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-22): Received evidence that borrower received disclosure within timing requirements.

11/22/2016

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201058446

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201058446

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-11-22): Lender contact is a CS Rep and doesn't have a unique identifier.

11/22/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058446

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Servicing Missing

TILA-RESPA Integrated Disclosure - Other Considerations: Loan Estimate provided on[MM/DD/YYYY] did not disclose the Servicing statement. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-18): Data was corrected on subsequent disclosures (SFIG).

11/18/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201058446

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $450.00 exceeds tolerance of $385.00. (7506)

Reviewer Comment (2016-11-18): Lender cured on final CD.

11/18/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058446

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $250.00 exceeds tolerance of $50.00. (7520)

Reviewer Comment (2016-11-18): Lender cured on the final CD.

11/18/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058446

Credit

Credit

Credit Documentation

Aged document: Credit Report is older than guidelines permit

Credit Report: Original // Borrower:

Lender approved exception for allowance of 91 day old Credit Report.

Residual Income required $1950; actual $6318.30, exceeds by $4368.30 12 months cash reserves required.  Borrower has 19 months. Max DTI 43%; actual 39.58%

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201058446

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Issue:  Ineligible borrower

Foreign National Guidelines do not allow Borrower's with current Visa's.  Lender approved exception.

Residual Income required $1950; actual $6318.30, exceeds by $4368.30 12 months cash reserves required.  Borrower has 19 months. Max DTI 43%; actual 39.58%

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201058447

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

The CD reflects a closing date of [MM/DD/YYYY] vs. actual closing date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058447

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

The CD does not reflect the Lender's Loan Originator's NMLS number.

Reviewer Comment (2016-11-22): Lender contact is a CS Rep and doesn't have a unique identifier.

11/22/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058447

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

The CD reflects seller paid closing costs of $1,200 vs. seller's CD which reflects $42,207.61.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058447

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

14 months reserves > 3 months guideline minimum

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201058448

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-11-23): Lender contact is a CS Rep and doesn't have a unique identifier.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058448

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly amount reflects $231.25, however prepaid homeowner's insurance reflects $2970.00, should be $2775.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058448

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for (Lender Credit) of ($791.72) was not provided.

Reviewer Comment (2016-11-30): Data correct on subsequent CDs (SFIG). Reviewer Comment (2016-11-28): Received post close CD reflecting a cure of $791.72, but still missing LOE, copy of check, and proof of delivery.

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058448

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-16,623.20  is less than amount of binding Lender Credit previously disclosed in the amount of $-17,414.92. (9300)

Lender Credit disclosed as ($-17,414.92) on (CD dated [MM/DD/YYYY]), but disclosed as ($-16,623.20) on Final Closing Disclosure.

Reviewer Comment (2016-11-30): Subsequent CDs reflect the credits reflected in incorrect section in the correct section.  Total credits reflect the same amount as on LE. Reviewer Comment (2016-11-28): Received post close CD reflecting a cure of $791.72, but still missing LOE, copy of check, and proof of delivery.

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058448

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $58,889.80, while closing CD seller's fees total $48,946.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201058449

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

Reviewer Comment (2016-11-22): Re-Evaluation reflects no violation.

11/22/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201058449

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-12): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201058449

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Reviewer Comment (2016-12-12): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058449

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,000.00 exceeds tolerance of $0.00. (7200)

COC form in file only indicates Courtesy Re-disclosure with a $2K discount fee added.  The rate lock did not expire and no terms of loan changed.

Reviewer Comment (2016-12-12): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058449

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201058449

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

56 months reserves > 3 months guideline minimum - borrowers have verified reserves of $x,xxx.xx

Reviewer Comment (2016-11-18): Client elects to waive.

11/18/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201058450

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-23): Received evidence that borrower received disclosure within timing requirements.

11/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201058450

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-11-23): Lender contact is a CS Rep and doesn't have a unique identifier.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058450

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-11-23): Received evidence that borrower received disclosure within timing requirements.

11/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201058450

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $44,996.25, while closing CD seller's fees total $44,892.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201058450

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $0.00. (7580)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2016-11-19): Cure provided on Final CD.

11/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058450

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-11-30): Received evidence that borrower received disclosure within timing requirements.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201058450

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.14890% or Final Disclosure APR of 6.14900% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201058450

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00. (75106)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2016-11-19): Cure  provided on Final CD.

11/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201058450

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

40% DTI  < 50% guideline max - 10% below program guideline maximum

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201061270

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Reviewer Comment (2016-11-28): Received evidence that appraisal was performed after disaster, as noted to by appraiser.

11/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201061270

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.91070% or Final Disclosure APR of 8.91100% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201061270

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $4267.92, while closing CD seller's fees total $3713.92.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201061270

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

48 months reserves > 3 months guideline minimum

Reviewer Comment (2016-11-28): Clients elect to waive.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201061271

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Reviewer Comment (2016-11-30): Received copy of executed Note.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

D

A

D

A

D

A

D

A

D

A

Non QM

Non QM

No

D

B

201061271

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.38210% or Final Disclosure APR of 8.38200% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

D

B

201061271

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

(Initial LE) disclosure(s) was issued on the "With Seller" form, and (All Other) disclosure(s) was issued on the "Without Seller" form.

Reviewer Comment (2016-11-19): Data was corrected on subsequent disclosures (SFIG).

11/19/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201061271

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-11-23): Lender contact is a CS Rep and doesn't have a unique identifier.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

D

B

201061271

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly amount reflects $133.08, however prepaid homeowner's insurance reflects $785.00, should be $1596.96.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201061271

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

35% DTI < 50% guideline max - 15% below program guideline maximum 680 representative FICO score > 620 guideline minimum - 60 points above guideline minimum 42 months reserves > 6 months guideline minimum

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201061271

Credit

Credit

Misc

Credit Exception:

Lender approved exception to allow cash out refinance with non-traditional credit. Per guidelines only purchase and rate term transactions are allowed to use non-traditional credit.

35% DTI < 50% guideline max - 15% below program guideline maximum 680 representative FICO score > 620 guideline minimum - 60 points above guideline minimum 42 months reserves > 6 months guideline minimum

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201061273

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant.  Seller paid fees on Sellers Closing Disclosure are not consistent with those reflected on the Borrowers Final Closing Disclosure.  Sellers CD reflects $16,585.00 in seller paid fees.  Combined CD does not reflect any seller paid fees

Reviewer Comment (2016-11-28): Data correct on subsequent CDs (SFIG).

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201061273

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Non-Warrantable Condo Tier 1, maximum DTI of 43%, lender approved exception allowing a DTI of 50%; however, lender did not include the correct amount of taxes/insurance on the subject.  Actual DTI is 50.18509% and exceeds approved exception amount.

75% LTV < 90% guideline max 119 months reserves > 9 months guideline minimum Borrower on this full documentation loan has a disposable income of $5,317.29

Reviewer Comment (2016-11-25): Client elects to waive.

11/25/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201061273

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

75% LTV < 90% guideline max 119 months reserves > 9 months guideline minimum Borrower on this full documentation loan has a disposable income of $5,317.29

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201064067

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.07140% or Final Disclosure APR of 8.07100% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201064067

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.07140% or Final Disclosure APR of 8.07100% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201064067

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

E-sign disclosure has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201064067

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Notary date on Security Instrument is [MM/DD/YYYY], final CD reflects a closing date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201064067

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant.  Seller paid fees on Sellers Closing Disclosure are not consistent with those reflected on the Borrowers Final Closing Disclosure.  Sellers CD reflects $20,652.85 in seller paid fees.  Combined CD disclosed $18,698.70 in seller paid fees.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201064067

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception

Consistent on time housing payment history at primary residence for 24 months when 12 months is required.  On time mortgage history for 11 months, VOR for 13 months. Borrower on this full documentation loan has a disposable income of $6,528.06

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201064067

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Consistent on time housing payment history at primary residence for 24 months when 12 months is required.  On time mortgage history for 11 months, VOR for 13 months. Borrower on this full documentation loan has a disposable income of $6,528.06

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201064069

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Reviewer Comment (2016-11-28): Life Insurance Surrender value added to reserves.  Requirements met.

11/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201064069

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD fees are $22,516.66, CD seller paid fees totaled $21,243.62.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201064069

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

Missing CDA or AVM.

Borrower on this loan has a disposable income of $4616

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201064070

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

Lender used gift funds to cover reserve requirement; guidelines only allow gift funds on purchase transaction. Lender exception approval in file.

Guideline variance approved by lender at time of origination. Residual Income: Minimum guideline requirements $1900.  Actual amount $9045 exceeds by $7145. Guideline variance approved by lender at time of origination. Debt-to-Income Ratio: Maximum allowed 43%. Actual 36.3316%

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201064070

Credit

Credit

Misc

Credit Exception:

Lender excluded a co-signed liability from the DTI when the proof of payment is a bank account from the Primary Obligors spouse and not the primary obligor. The borrower co-signed on a mtg for her daughter and the payments are coming from the daughters husbands acct. Lender exception approval in file.

Guideline variance approved by lender at time of origination. Residual Income: Minimum guideline requirements $1900.  Actual amount $9045 exceeds by $7145. Guideline variance approved by lender at time of origination. Debt-to-Income Ratio: Maximum allowed 43%. Actual 36.3316%

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201064070

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.83490% or Final Disclosure APR of 6.83500% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201064070

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.83490% or Final Disclosure APR of 6.83500% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201064070

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Initial Loan Estimate did not use Without Seller

Reviewer Comment (2016-11-21): Cured on following LE

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201064070

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

No evidence of receipt date in file

Reviewer Comment (2016-11-23): Received evidence that borrower received disclosure within timing requirements.

11/23/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201064070

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID missing

Reviewer Comment (2016-11-23): Lender contact is a CS Rep and doesn't have a unique identifier.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201064070

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $475.00. (7506)

Reviewer Comment (2016-11-21): Cured on closing CD.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201064070

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Guideline variance approved by lender at time of origination. Residual Income: Minimum guideline requirements $1900.  Actual amount $9045 exceeds by $7145. Guideline variance approved by lender at time of origination. Debt-to-Income Ratio: Maximum allowed 43%. Actual 36.3316%

Reviewer Comment (2016-11-21): Client elects to waive.

11/21/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201069101

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

19% DTI on this full documentation loan < 50% guideline max - 31% below program guideline maximum

Reviewer Comment (2016-11-23): Client elects to waive.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201069101

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.06880% or Final Disclosure APR of 9.09400% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201069102

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-30): Data correct on subsequent CDs (SFIG).

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201069102

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing vs Closing Disclosure

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Received attestation that disclosure was produced for fee review and never presented to borrower.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201069102

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

24% DTI on this full documentation loan < 50% guideline max - 26% below program guideline maximum

Reviewer Comment (2016-11-23): Client elects to waive.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201069103

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201069103

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

The final CD does not reflect the Lender's Loan Originator's NMLS number.

Reviewer Comment (2016-11-28): Lender contact is a CS Rep and doesn't have a unique identifier.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201069103

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-30): Received further clarification that while the rate was already locked, the FICO score associated with the lock went down (evidenced by credit report from submission).  CoC is now valid and change does not require a refund.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201069103

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

The final CD reflects seller paid closing cost of $49,899.53 vs. the seller's CD which reflects $51,597.03.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201069103

Credit

Credit

Misc

Credit Exception:

Residual income fail; required $5,900; Actual $4,562.65; Difference ($1,337.53).  Lender approved exception.

Spouse is not on the loan. W2 in the file for her shows she made $68,697.20 in 2015. Bank statements show payroll deposits every 2 weeks. With this additional income, Residual Incme would be a Pass with positive flow of $4,387.41. LTV 80% is less than max per program of 90%. 13 months verified reserves is greater than 3 months reserves required per program.

Reviewer Comment (2016-11-23): Client elects to waive.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201069103

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,023.56 exceeds tolerance of $418.00. (7200)

COC form in file indicates borrower interest rate change; however, loan was previously locked, lock had not expired at close and the rate remained the same with no valid COC provided for increase in discount points.

Reviewer Comment (2016-11-30): Received further clarification that while the rate was already locked, the FICO score associated with the lock went down (evidenced by credit report from submission).  CoC is now valid and change does not require a refund.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201069103

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Reviewer Comment (2016-11-30): Received further clarification that while the rate was already locked, the FICO score associated with the lock went down (evidenced by credit report from submission).  CoC is now valid and change does not require a refund.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201069104

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.03720% or Final Disclosure APR of 6.03700% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201069104

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

No evidence of receipt date in file

Reviewer Comment (2016-11-28): Received evidence that borrower received disclosure within timing requirements.

11/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201069104

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201069104

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $550.00. (7506)

$200.00 Cure was provided.

Reviewer Comment (2016-11-22): Lender cured on final CD with a $200 tolerance cure.

11/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201069104

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

Residual Income: Minimum guideline requirements $7550.  Actual amount $8155.99 exceeds by $605.99. Cash reserves: Minimum guideline requirements 3 months. Actual amount 31 months.

Reviewer Comment (2016-11-23): Client elects to waive.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201069104

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Residual Income: Minimum guideline requirements $7550.  Actual amount $8155.99 exceeds by $605.99. Cash reserves: Minimum guideline requirements 3 months. Actual amount 31 months.

Reviewer Comment (2016-11-23): Client elects to waive.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201091455

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for (Lender Credit) of ($520.00) was not provided.

Reviewer Comment (2016-12-06): Received corrected CD reflecting lender credit in correct section.  No violation.

12/06/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201091455

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-520.00. (9300)

Fee disclosed as ($-520.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($0.00) on Final Closing Disclosure.

Reviewer Comment (2016-12-06): Received corrected CD reflecting lender credit in correct section.  No violation.

12/06/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201091455

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $36,246.00, while closing CD seller's fees total $42,695.80.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201091456

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (1st Lien, Escrow Not Established)

Federal Higher-Priced Mortgage Loan (2013): Mandatory escrow account not established on 1st lien mortgage loan.

HO-6 insurance policy was not escrowed.

Reviewer Comment (2017-01-27): Received evidence that HO-6 was added to escrow.  Escrow account now accurate. Reviewer Comment (2016-12-01): The instruction that I received from Compliance has been reversed and the exception found to be valid. Reviewer Comment (2016-11-30): Escrow account set up is sufficient for Condos.

01/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201091456

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.02700% or Final Disclosure APR of 6.02700% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-01-27): Correct escrow account established. Reviewer Comment (2016-12-01): The instruction that I received from Compliance has been reversed and the exception found to be valid. Reviewer Comment (2016-11-30): Escrow account set up is sufficient for Condos.  File is Compliant HPML.  Correct exception re-set.

01/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201091456

Compliance

Compliance

State Compliance

North Carolina Rate Spread Threshold Test

North Carolina Rate Spread Home Loan: APR on subject loan of 6.02700% or Final Disclosure APR of 6.02700% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Rate Spread Home Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201091456

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-30): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201091456

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

Reviewer Comment (2016-11-29): Received evidence that borrower received disclosure within timing requirements.

11/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201091456

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-4,551.37  is less than amount of binding Lender Credit previously disclosed in the amount of $-4,725.00. (9300)

Reviewer Comment (2016-11-30): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201091456

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201091456

Credit

Credit

Misc

Credit Exception:

Lender exception in file for allowing appraisal with only 5 closed comps when 6 are required per guidelines.

Required Income: $4700.00; Verified: $17,989.31; Excess of $13,289.31 Number of months verified reserves: $388,828-$187,139 CTC = $201,689/$6,162.67 = 32.72 months in post-closing reserves.  Guidelines require 3 months.

Reviewer Comment (2016-11-25): Client elects to waive.

11/25/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201091456

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.02700% or Final Disclosure APR of 6.02700% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2016-12-01): The instruction that I received from Compliance has been reversed and the exception found to be valid.  EV3 is the correct level.

12/01/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201091456

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201091457

Credit

Loan Package Documentation

Application / Processing

Missing Document: Divorce Decree / Child Support not provided

Borrower must provide both a (i) copy of final divorce decree, legal separation agreement, court order or voluntary payment agreement and (ii) acceptable evidence that payments have been received during the last 12 months, such as cancelled checks, deposit slips, tax returns or court records

Reviewer Comment (2016-11-28): Received required divorce documentation.

11/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201091457

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.92100% or Final Disclosure APR of 5.92500% is in excess of allowable threshold of APOR 3.17% + 2.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201091457

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $180.30 exceeds tolerance of $60.00. (7520)

Reviewer Comment (2016-11-23): Lender cured on final CD with $120.30 cure.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201091457

Credit

Credit

Credit Eligibility

Guideline Issue:  Foreclosure timeline outside of credit guidelines

HELOC Charge-off only years at application, per guidelines 4 years is required.

Reviewer Comment (2016-11-30): Client has elected to use property sale date rather than judgment satisfaction date as basis for derogatory credit timing testing.  Using that date, the event was within guideline requirements.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201091457

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2016-11-28): Received acceptable fraud report.

11/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201091457

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-13): Designation switched to Rebuttable presumption.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201091458

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.02200% or Final Disclosure APR of 6.02200% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201091458

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-11-29): Lender contact is a CS Rep and doesn't have a unique identifier.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201091458

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Disposable income discrepancy.

Lender approved exception.

72% LTV < 80 guideline maximum Borrower has demonstrated a satisfactory housing history for 36 months, 0x24 is required per guidelines.

Reviewer Comment (2016-11-28): Client elects to waive.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201091458

Compliance

Compliance

State Compliance

Michigan CMPA Home Loan Toolkit Timing

Michigan Consumer Mortgage Protection Act:  Home Loan Toolkit not provided to borrower within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201091458

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $34.35 exceeds tolerance of $0.00. (7520)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2016-11-28): Cure provided on Final CD.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201091458

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

72% LTV < 80 guideline maximum Borrower has demonstrated a satisfactory housing history for 36 months, 0x24 is required per guidelines.

Reviewer Comment (2016-11-28): Client elects to waive.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201091459

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.34120% or Final Disclosure APR of 9.34100% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201091459

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Missing Lender's Contact NMLS ID.

Reviewer Comment (2016-12-02): Lender contact is a CS Rep and doesn't have a unique identifier.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201091459

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

Missing Clear Captial CDA or CoreLogic AVM reviews.

32% DTI on this (Documentation Type) documentation loan < 50% guideline max - 18% below program guideline maximum

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201091460

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approves exception

Guideline variance approved by lender at time of origination:  residual income well above minimum required, and dti significantly below max Guideline variance approved by lender at time of origination:  residual income well above minimum required, and dti significantly below max

Reviewer Comment (2016-11-25): Client elects to waive.

11/25/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201091460

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.08690% or Final Disclosure APR of 8.08700% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201091460

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201091460

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-11-28): Received evidence that borrower received disclosure within timing requirements.

11/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201091460

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-28): Lender contact is a CS Rep and doesn't have a unique identifier.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201091460

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201091460

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title agent reflected on SSPL and title fees reflected in Section C versus Section B.  Title commitment indicates closing agent is the issuing agent.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201091460

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201091460

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00. (7580)

Reviewer Comment (2016-11-23): Lender cured on the final CD with a $2 tolerance cure.

11/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201091461

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.55400% or Final Disclosure APR of 6.55400% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201091461

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Missing secondary valuation.

53 months reserves > 3 months guideline minimum

Reviewer Comment (2016-12-07): Client elects to waive.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201091461

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Lender contact is a CS Rep and doesn't have a unique identifier.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201091461

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/102284)

Per HOI Dec page in file, premium amount is $2997.72, Final CD reflects $1641.88.

Reviewer Comment (2016-12-07): Received HOI used for escrow payments.  Wasn't supplied in original submission.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201091461

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/102285)

Per HOI Dec page in file, premium amount is $2997.72, Final CD reflects $1641.88.

Reviewer Comment (2016-12-07): Received HOI used for escrow payments.  Wasn't supplied in original submission.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201091461

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/102286)

Per HOI Dec page in file, premium amount is $2997.72, Final CD reflects $1641.88.

Reviewer Comment (2016-12-07): Received HOI used for escrow payments.  Wasn't supplied in original submission.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201091461

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/102287)

Per HOI Dec page in file, premium amount is $2997.72, Final CD reflects $1641.88.

Reviewer Comment (2016-12-07): Received HOI used for escrow payments.  Wasn't supplied in original submission.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201091461

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201091461

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/102284)

Per HOI Dec page in file, premium amount is $2997.72, Final CD reflects $1641.88.

Reviewer Comment (2016-12-07): Received HOI used for escrow payments.  Wasn't supplied in original submission.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201091462

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-11-29): Lender contact is a CS Rep and doesn't have a unique identifier.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201091462

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $31,465.30, while closing CD seller's fees total $43,615.19.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201091462

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-14,522.50  is less than amount of binding Lender Credit previously disclosed in the amount of $-14,522.70. (9300)

Fee disclosed as ($-14,522.70) on (CD dated [MM/DD/YYYY]), but disclosed as ($-14,522.50) on Final Closing Disclosure.

Reviewer Comment (2016-11-28): Cured at closing.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201091462

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

TILA-RESPA Integrated Disclosure: Settlement Service Provider List did not provide at least one available provider for each settlement service borrower is entitled to shop for or inform borrower they may choose different provider from list.

Settlement Service Provider List in file is not TRID compliant (references GFE).

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201091463

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

The Note is not signed by the borrower

Reviewer Comment (2016-11-30): Received executed copy of Note.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201091463

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.64770% or Final Disclosure APR of 6.64800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201091463

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

The lender contact NMLS ID is missing on the final CD.

Reviewer Comment (2016-11-28): Lender contact is a CS Rep and doesn't have a unique identifier.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201091463

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant.  Seller paid fees on Sellers Closing Disclosure are not consistent with those reflected on the Borrowers Final Closing Disclosure.  Sellers CD reflects $22,815 in seller paid fees.  Combined CD disclosed $3,750 in seller paid fees.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201091463

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00. (75106)

Lender credit in the amount of $150.00 was disclosed on the final CD to cure the under disclosure for the CDA.

Reviewer Comment (2016-11-25): Cured at closing.

11/25/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106058

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.87690% or Final Disclosure APR of 6.87700% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201106058

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $40,956.00, while closing CD seller's fees total $365.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201106058

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $113.00 exceeds tolerance of $100.00 plus 10% or $110.00 (0)

($3.00) violation due to increase in (Recording fee(s)).

Reviewer Comment (2016-11-28): Lender cured on final CD with $153 tolerance cure.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106058

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $450.00. (7506)

Fee disclosed as ($450.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($600.00) on Final Closing Disclosure.

Reviewer Comment (2016-11-28): Lender cured on final CD with $153 tolerance cure.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106058

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

38 months reserves > 3 months guideline minimum

Reviewer Comment (2016-11-28): Client elects to waive.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201106059

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account Statement Missing

RESPA (2010): Initial escrow account statement was not provided to the borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201106059

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Received evidence that borrower received disclosure within timing requirements.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201106059

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Purchase Agreement reflects $5000 EMD that wasn't listed on CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106059

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106059

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

Missing Clear Capital CDA or Corelogic AVM.

25% DTI on this full documentation loan < 50% guideline max - 25% below program guideline maximum

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201106060

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.83940% or Final Disclosure APR of 6.83900% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Loan.

All fees are verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201106060

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender contact NMLS ID is missing on the final CD.  Data is still not accurate on subsequent CD.

Reviewer Comment (2016-11-29): Lender contact is a CS Rep and doesn't have a unique identifier.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106060

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $4.80.  Calculates to be $67.30.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106060

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Cure of ($4.80) was reflected, which is insufficient to cure ($67.30)

Reviewer Comment (2016-11-30): Fees were originally in the incorrect section.  Subsequent CD has fees listed in correct section, so they are not subject to tolerance testing.  No violation.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201106060

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Missing secondary valuation.

Reviewer Comment (2016-11-29): Exception was erroneously set as Compliance violation rather then a Credit violation.  This exception reset and new one created. Reviewer Comment (2016-11-29): should have been waived with Comp Factor. Reviewer Comment (2016-11-28): Client elects to waive.

11/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201106060

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Sellers CD reflects $37,992.76.  Borrwer's  CD reflects $30,366.70.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106060

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $59.80 exceeds tolerance of $55.00. (7520)

Reviewer Comment (2016-11-28): Finacl CD reflects $4.80 Lender Credit for tolerance cure.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106060

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - SubEscrow Fee.  Fee Amount of $62.50 exceeds tolerance of $0.00. (75201)

Fee not disclosed on LE.

Reviewer Comment (2016-11-30): Fees were originally in the incorrect section.  Subsequent CD has fees listed in correct section, so they are not subject to tolerance testing.  No violation.

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201106060

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender Approved.

Residual Income: Minimum guideline requirements $4300. Actual amount $16,700,  Exceeds by $12400. DTI: Maximum allowed 50%.  Actual 31%.

Reviewer Comment (2016-11-28): Client elects to waive.

11/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201106060

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Notary, Sub-Escrow and Endorsement fees reflected in section B, should be in section C.  Provider used is not listed on the SSPL.   Data is still not accurate on subsequent CD.

Reviewer Comment (2016-11-30): Data correct on subsequent CDs (SFIG).

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106060

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Residual Income: Minimum guideline requirements $4300. Actual amount $16,700,  Exceeds by $12400. DTI: Maximum allowed 50%.  Actual 31%.

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201106061

Compliance

Compliance

State Compliance

Connecticut HB5577 NP Threshold Test ARM Loans

Connecticut Non-Prime Home Loan: APR on subject loan of 6.62690% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201106061

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender contact NMLS ID is blank on the final CD.

Reviewer Comment (2016-12-02): Lender contact is a CS Rep and doesn't have a unique identifier.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201106061

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Final CD disclosed 12 months prepaid hazard insurance of 168.40.  Monthly premium is 42.17.  Prepaid hazard insurance should be disclosed as 4 months.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201106061

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

A lender exception has been approved to allow proceeds from cash out refinance to be considered for borrowers reserves.  Exception has been indexed in the document inventory, compensating factors have been added.

43% DTI on this full documentation loan < 50% guideline max 42.195% LTV < 85% guideline max - Residual income is 1588.52, exceeds required residual of $600.00

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201106061

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

A lender exception has been approved for credit score requirement for non-warrantable condo.  Exception has been indexed in the document inventory, compensating factors have been added.

43% DTI on this full documentation loan < 50% guideline max 42.195% LTV < 85% guideline max - Residual income is 1588.52, exceeds required residual of $600.00

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201106061

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $85.00. (7580)

Reviewer Comment (2016-11-29): Cured with refund on closing CD

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106061

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

43% DTI on this full documentation loan < 50% guideline max 42.195% LTV < 85% guideline max - Residual income is 1588.52, exceeds required residual of $600.00

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

Non QM

Non QM

No

C

B

201106221

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-06): Received evidence that borrower received disclosure within timing requirements.

12/06/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201106221

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2016-12-07): Data correct on subsequent CDs (SFIG).

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106221

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-12-02): Received evidence that borrower received disclosure within timing requirements.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201106221

Credit

Credit

Misc

Credit Exception:

Lender approved exception for  Credit event seasoning  with a BK 13 in  and deed in lieu of foreclosure  within 2 years seasoning.

Over 24 months housing history verified. Residual income of $3,854 with a guideline minimum requirement $1,850. DTI is below guideline maximum of 43%..

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201106221

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Guidelines require a secondary valuation report that was not provided.

Over 24 months housing history verified. Residual income of $3,854 with a guideline minimum requirement $1,850. DTI is below guideline maximum of 43%..

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201106221

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender approved exception was provided.

Over 24 months housing history verified. Residual income of $3,854 with a guideline minimum requirement $1,850. DTI is below guideline maximum of 43%..

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201106221

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender approved exception was provided.

Over 24 months housing history verified. Residual income of $3,854 with a guideline minimum requirement $1,850. DTI is below guideline maximum of 43%..

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201106221

Compliance

Compliance

State Compliance

South Carolina Home Loan (Acknowledgement of Receipt of Complaint Agency Disclosure Not In File)

South Carolina Home Loan: Borrower did not acknowledge receipt of document specifying the agency designated to receive complaints or inquiries about the origination and making of the loan.

Reviewer Comment (2016-12-02): Receive executed copy of disclosure.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201106221

Credit

Credit

Misc

Credit Exception:

Missing full transcripts for borrower to verify no SE loss or Sch A deductions are required to be added to DTI calcs.  Transcripts in file are only W2 transcript verification.

Reviewer Comment (2016-12-15): Client attests that W2 transcripts meet guideline requirements. Reviewer Comment (2016-12-12): Guidelines quoted are not the guidelines used in review.  Used guidelines issued 10/16 which do not contain the provisions quoted in rebuttal.  Per guides:  Wage Earners: IRS Form 4506T is required to be signed and executed during the origination process and transcript documentation must be provided in the closed file. Reviewer Comment (2016-12-06): Per guidelines:  Wage Earners: IRS Form 4506T is required to be signed and executed during the origination process and transcript documentation must be provided in the closed file.

12/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201106223

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2016-12-02): File switched to Non-QM.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106223

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.30360% or Final Disclosure APR of 7.31400% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201106223

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual consummation date is [MM/DD/YYYY]

Reviewer Comment (2016-11-30): Data correct on subsequent CDs (SFIG).

11/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201106223

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201106223

Compliance

Compliance

Federal Compliance

Self Employed YTD

Qualified Mortgage (Dodd-Frank 2014): Self-employed qualifying income reflects a declining earnings trend.

P&L does not break out borrower's YTD Wage income.  Per documentation in file, company has a downward income earnings trend which makes it ineligible for Appendix Q.  Please provide amount that borrower has received so far this year in order for this to be entered into income calculations.

Reviewer Comment (2016-12-02): File switched to Non-QM

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201106223

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201106223

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

22 months reserves > 9 months guideline minimum

Reviewer Comment (2016-11-30): Client elects to waive.

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201106224

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.17920% or Final Disclosure APR of 7.17900% is in excess of allowable threshold of APOR 3.58% + 1.5%, or 5.08000%.  Non-Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

Reviewer Comment (2016-12-13): Exception was set as a non-compliant HPML loan based on the second appraisal charged to the consumer, the lender provided a credit at closing to remediate the charge for the second appraisal, therefore this HPML Threshold loan is compliant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201106224

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD reflects a closing date of [MM/DD/YYYY] with a disbursement date of [MM/DD/YYYY].  Notary date on security instrument is [MM/DD/YYYY].  Final CD was signed [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201106224

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-11-30): Cured at closing.

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201106224

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Erroneous exception:  Lender credit of $2,225.00 was disclosed on the final CD to cure the under disclosure of the appraisal fees.

Reviewer Comment (2016-11-29): Cured at closing.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106224

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $725.00 exceeds tolerance of $575.00. (7506)

Reviewer Comment (2016-11-29): Cured at closing.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106224

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

A lender exception has been approved for DTI of 55.75.  Exception has been indexed in the document inventory, compensating factors have been added.  **Borrower was required to payoff a revolving debt through closing in order to bring DTI to 55.75.  Evidence of the debt payoff is not on the CD.  DTI is calculated at 58.953.

Residual Income: Borrowers residual income is $1240, which is above the required amount of $1000. Reserves: Borrowers have 130 months reserves.  Program requirements is 3 months. LTV: The LTV is 80%.  Maximum is 85%

Reviewer Comment (2016-12-13): Received updated lender exception to allow for correct DTI.  Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201106224

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals.

The borrower was charged for two appraisals, fix and flip requires lender to pay the second appraisal.

Reviewer Comment (2016-12-12): Cleared based on lender credit for appraisal supplied at closing. Reviewer Comment (2016-11-30): Lender credit at closing.

12/12/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201106224

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant.  Seller paid fees on Sellers Closing Disclosure are not consistent with those reflected on the Borrowers Final Closing Disclosure.  Sellers CD reflects $20,605.50 in seller paid fees.  Combined CD disclosed $18,650.00 in seller paid fees

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201106224

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $725.00 exceeds tolerance of $0.00. (7507)

Reviewer Comment (2016-11-30): Cured at closing.

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106224

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Residual Income: Borrowers residual income is $1240, which is above the required amount of $1000. Reserves: Borrowers have 130 months reserves.  Program requirements is 3 months. LTV: The LTV is 80%.  Maximum is 85%

Reviewer Comment (2016-11-30): Client elects to waive.

11/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201106225

Compliance

Compliance

State Compliance

Minnesota Subprime Threshold Test Fixed Loan

Minnesota Subprime Loan: APR on subject loan of 6.56920% or Final Disclosure APR of 6.56900% is in excess of allowable threshold of USTreasury 2.4800% + 3%, or 5.48000%.  Compliant Subprime Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

D

B

201106225

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Lender contact is a CS Rep and doesn't have a unique identifier.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

D

B

201106225

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-07): Data correct on subsequent CDs (SFIG).

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

D

B

201106225

Credit

Credit

Misc

Credit Exception:

Required residual income for a family of 4 is $6,350 and actual is $5,852.

13 months reserves > 9 months guideline minimum. Payment shock is 53%.

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201106225

Compliance

Compliance

Federal Compliance

TRID - the file contains an illegible TRID disclosure. Testing is incomplete

CD is not complete.

Reviewer Comment (2016-12-07): Received attestation that disclosure was produced by title and never presented to borrower. Buyer Comment (2016-12-06): Please disregard first upload [MM/DD/YYYY] 1:57pm

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

B

D

B

D

B

D

B

Non QM

Non QM

Yes

D

B

201106225

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

There is no secondary valuation in file.

13 months reserves > 9 months guideline minimum. Payment shock is 53%.

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201106226

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.14520% or Final Disclosure APR of 6.14500% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201106226

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.14520% or Final Disclosure APR of 6.14500% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201106226

Credit

Credit

Misc

Credit Exception:

DTI ratio of 52.32% exceeds 43% max allowed with 85% LTV,  Lender approved at 52.713%, exception was provided in file.

Borrower on this full documentation loan has a disposable income of $10,180 which is above the required amount of $7,200. 14 months reserves > 6 months guideline minimum. Primary housing history has been paid as agreed with no lates- 37 mos.

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201106226

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Lender contact is a CS Rep and doesn't have a unique identifier.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201106226

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201106226

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-07): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2016-12-02): The exception isn't referring to the 10/20 LE, it's referring that the first LE received was issued 10/20.  We're missing the initial LE sent out by the broker within 3 days of application, 10/14.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201106226

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201106226

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $150.00 exceeds tolerance of $135.00 plus 10% or $148.50 (0)

Reviewer Comment (2016-11-29): Cured on closing CD with $1.50 refund.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201106226

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

There is no secondary valuation in file.

Borrower on this full documentation loan has a disposable income of $10,180 which is above the required amount of $7,200. 14 months reserves > 6 months guideline minimum. Primary housing history has been paid as agreed with no lates- 37 mos.

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201106227

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Received evidence that borrower received disclosure within timing requirements.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201106227

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201106227

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

Missing Clear Capital CDA or Corelogic AVM.

29% DTI on this full documentation loan < 50% guideline max - 21% below program guideline maximum

Reviewer Comment (2016-12-07): Client elects to waive.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201106442

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.61610% or Final Disclosure APR of 6.61600% is in excess of allowable threshold of APOR 3.19% + 1.5%, or 4.69000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-01-23): Lvl 1

01/23/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

A

A

201108291

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $34,726.05, while closing CD seller's fees total $48,223.07.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201108291

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

38% DTI on this  loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201108292

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.89650% or Final Disclosure APR of 6.89700% is in excess of allowable threshold of APOR 3.49% + 2.5%, or 5.99000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201108292

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.89650% or Final Disclosure APR of 6.89700% is in excess of allowable threshold of APOR 3.49% + 2.5%, or 5.99000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201108292

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $180.00 exceeds tolerance of $110.00 plus 10% or $121.00 (0)

($59.00) violation due to increase in (Recording fee(s)).

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201108292

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00. (75106)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201108292

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $63.72 exceeds tolerance of $50.00. (7520)

Fee disclosed as ($50.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($63.72) on Final Closing Disclosure.

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201108293

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.28090% or Final Disclosure APR of 8.28100% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201108293

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

(Initial LE) disclosure(s) was issued on the "With Seller" form, and (All Other) disclosure(s) was issued on the "Without Seller" form.

Reviewer Comment (2016-12-01): Data was corrected on subsequent disclosures (SFIG).

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201108293

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

Reviewer Comment (2016-12-01): Data was corrected on post close CD (SFIG).

12/01/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201108293

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lender Contact NMLS ID is blank.

Reviewer Comment (2016-12-06): Lender contact is a CS Rep and doesn't have a unique identifier.

12/06/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201108293

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on [MM/DD/YYYY], prior to three (3) business days from transaction date of [MM/DD/YYYY].

Disbursement date of [MM/DD/YYYY] reflected on Final CD is same as Right to Cancel Expiration date of [MM/DD/YYYY].

Reviewer Comment (2016-12-01): Data was corrected on post close CD (SFIG).

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201108293

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

727 representative FICO score > 620 guideline minimum - 107 points above guideline minimum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201108293

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $450.00 exceeds tolerance of $400.00. (7506)

Fee disclosed as ($400.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($450.00) on Final Closing Disclosure.

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201108293

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $73.60 exceeds tolerance of $50.00. (7520)

Fee disclosed as ($50.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($73.60) on Final Closing Disclosure.

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201108293

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $69.00. (7580)

Fee disclosed as ($69.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($92.00) on Final Closing Disclosure.

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201108294

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $77.24 exceeds tolerance of $60.00. (7520)

Fee disclosed as ($60.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($77.24) on Final Closing Disclosure.

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201108294

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception. LTV of 80% exceeds maximum LTV allowed of 70% with minimum credit score of 580.

Borrower on this full documentation loan has a residual income of $12,603.87  ($2750 required) 40.52% DTI on this full documentation loan < 50% guideline max - 9.5% below program guideline maximum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201108294

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

Borrower on this full documentation loan has a residual income of $12,603.87  ($2750 required) 40.52% DTI on this full documentation loan < 50% guideline max - 9.5% below program guideline maximum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201108295

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $12,156.25, while closing CD seller's fees total $800.00.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201108296

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $22,502.49, while closing CD seller's fees total $2000.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201108296

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

36% DTI on this loan < 50% guideline max - 14% below program guideline maximum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201108297

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201108297

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $635.00 exceeds tolerance of $535.00. (7506)

Fee disclosed as ($535.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($635.00) on Final Closing Disclosure.

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201108297

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

789 representative FICO score > 660 guideline minimum - 129 points above guideline minimum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201108298

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

The file is missing the secondary valuation.

Borrowers on this Full documentation loan have a disposable income of $4,837.66. Borrowers have 10.31 months in verified reserves which is > 6 months reserves required per program.

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201108298

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.29490% or Final Disclosure APR of 8.30000% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201108298

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

The final CD reflects seller paid closing costs of $24,899 vs. seller's CD which reflects $34,020.95.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201108298

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

1003 Error: Citizenship Source Documentation  was not provided

Borrower:

CoBorrower not a US Citizen and not a Permanent Resident Alien per 1003 however no other documentation in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201108299

Credit

Credit

Misc

Credit Exception:

Lender approved exceptions: 1. To use trust account in which our borrower is beneficiary per trustee letter in file. 2. Not to require a full 12 months of bank statements on the asset depletion program due to unique circumstances with the trust account. 3. Payment shock is 388.056% when the max is 250% for a first time home buyer for the co-borrower. Co-borrower is the fiance to the other borrower on our loan and has been living rent free with him.

Residual Income $4284.96,  Above the minimum required of $2700. Reserves of 89 months is in excess of the program minimum of 3 mos, LTV of 80% is below the program maximum of 90%.

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201108299

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $34,051.45, while closing CD seller's fees total $33,304.45.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201108299

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

Residual Income $4284.96,  Above the minimum required of $2700. Reserves of 89 months is in excess of the program minimum of 3 mos, LTV of 80% is below the program maximum of 90%.

Reviewer Comment (2016-12-12): Client elects to waive.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201108300

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of Non QM Fail.

Reviewer Comment (2016-12-02): Lender violations waived with Comp Factors.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201108300

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.03940% or Final Disclosure APR of 6.03900% is in excess of allowable threshold of APOR 3.27% + 2.5%, or 5.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201108300

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose number of months for homeowner's insurance under Prepaids. (Final/[MM/DD/YYYY])

Line 1 of Section F, number of months is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201108300

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $67,174.00, while closing CD seller's fees total $66,430.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201108300

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

15.78 months reserves > 3 months guideline minimum - borrowers have verified reserves of $92,325.21 70% LTV < 80 guideline max -  $196,000 more equity than required by program guidelines Verified mortgage history of 79 mos > 24 mos required

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201108300

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Disposable income discrepancy.

Lender approved exception.

15.78 months reserves > 3 months guideline minimum - borrowers have verified reserves of $92,325.21 70% LTV < 80 guideline max -  $196,000 more equity than required by program guidelines Verified mortgage history of 79 mos > 24 mos required

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201108300

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.03940% or Final Disclosure APR of 6.03900% is in excess of allowable threshold of APOR 3.27% + 2.5%, or 5.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201108300

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2016-12-02): Lender violations waived with Comp Factors.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201108300

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Employment Fee.  Fee Amount of $35.00 exceeds tolerance of $32.00. (7571)

Fee disclosed as ($32.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($35.00) on Final Closing Disclosure.

Reviewer Comment (2016-12-01): Cure provided on Final CD.

12/01/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201109646

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.65210% or Final Disclosure APR of 6.65900% is in excess of allowable threshold of APOR 3.49% + 1.5%, or 4.99000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201109646

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2016-12-05): Data was corrected on subsequent CDs (SFIG).

12/05/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109646

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow Account

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan will have an escrow account. (Final/[MM/DD/YYYY])

Erroneous. The loan does have an escrow account which was properly disclosed, however, the escrows collected at closing total $1,314.88 which is the same amount as the aggregate adjustment netting an initial escrow deposit of -0-.

Reviewer Comment (2016-12-07): No violation.  Escrow account is validly set up.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201109646

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Not Have Escrow Account

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan will have an escrow account. (Final/[MM/DD/YYYY])

Erroneous.The loan does have an escrow account which was properly disclosed, however, the escrows collected at closing total $1,314.88 which is the same amount as the aggregate adjustment netting an initial escrow deposit of -0-.

Reviewer Comment (2016-12-07): No violation.  Escrow account is validly set up.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201109646

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

Borrower's mortgage payment decreased by $661.00 per month

Reviewer Comment (2016-12-05): Lender elects to waive the exception.

12/05/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201109647

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-12-20): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2016-12-07): Disclosure sent in was signed 8/29 and index references Aug 19th.  We need evidence that the ARM disclosure was presented to borrowers within 3 days of application.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201109647

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

The lender did not disclose the fees in the correct section.  The Title fees were listed in Section C on the Loan Estimates and then moved to Section B of the Final Closing Disclosure.  The borrower chose the title company.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109647

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

Missing CDA or AVM.

23% DTI on this full documentation loan < 50% guideline max - 27% below program guideline maximum

Reviewer Comment (2016-12-07): Client elects to waive.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201109648

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly amount reflects $379.17, however prepaid homeowner's insurance reflects $1137.00, should be $4550.04..

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201109648

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-07): Received evidence that seller did not pay any fees.  CD accurate.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201109648

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Disclosure reflects Deposit = $0, however sales contract reflects that there was a deposit.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201109648

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure of ($170.00) was reflected, which is insufficient to cure ($224.60)

Reviewer Comment (2016-12-08): Cure at closing sufficient for tolerance violations.

12/08/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201109648

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,027.50 exceeds tolerance of $1,789.00 plus 10% or $1,967.90 (0)

($59.60) violation due to increase in (Title fee(s)).

Reviewer Comment (2016-12-08): Cure at closing sufficient for tolerance violations.

12/08/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201109648

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Cure of ($170.00) was reflected, which is insufficient to cure ($224.60)

Reviewer Comment (2016-12-08): Cure at closing sufficient for tolerance violations.

12/08/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201109648

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $450.00. (7506)

Fee disclosed as ($450.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($600.00) on Final Closing Disclosure.

Reviewer Comment (2016-12-02): Cure provided on Final CD.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201109648

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $15.00 exceeds tolerance of $0.00. (8304)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2016-12-02): Cure provided on Final CD.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201109648

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.88470% or Final Disclosure APR of 6.88500% is in excess of allowable threshold of APOR 3.58% + 2.5%, or 6.08000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201109649

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.29660% or Final Disclosure APR of 8.29700% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201109649

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.29660% or Final Disclosure APR of 8.29700% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201109649

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201109649

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

124 months reserves > 3 months guideline minimum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201109649

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201109650

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.41040% or Final Disclosure APR of 8.49000% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201109650

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $1064.00, while closing CD seller's fees total $850.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109650

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

725 representative FICO score > 620 guideline minimum - 105 points above guideline minimum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201109651

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-12-07): Received evidence that borrower received disclosure within timing requirements.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201109651

Credit

Credit

Misc

Credit Exception:

Secondary Valuation report not provided.

24% DTI on this full documentation loan < 50% guideline max - 26% below program guideline maximum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201109652

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

The note and final CD reflect a closing date of 11/1/16, signing / notary date did not take place until 11/2/16.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109652

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

There are no seller paid fees on this purchase transaction.  Sellers CD does not reflect any seller paid fees, final combined CD does not reflect any seller paid fees.  A lump sum seller credit in the amount of $8,947.00 is disclosed under the summaries of transactions.  Breakdown has not been provided.

Reviewer Comment (2016-12-16): Received evidence that Seller had no fees.

12/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201109652

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose number of months for Property Tax under Prepaids. (Final/[MM/DD/YYYY])

The number of months collected  field is blank under the prepaids on the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109652

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow Account

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan will have an escrow account. (Final/[MM/DD/YYYY])

It does not appear that the initial escrow deposit is calculated properly.  One month hazard and property tax has been collected on the final CD which were offset by the aggregate calculation making the initial escrow deposit -0-.  No cushion has been collected at closing.

Reviewer Comment (2016-12-07): No violation.  Escrow account is validly set up.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201109652

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Not Have Escrow Account

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan will have an escrow account. (Final/[MM/DD/YYYY])

It does not appear that the initial escrow deposit is calculated properly.  One month hazard and property tax has been collected on the final CD which were offset by the aggregate calculation making the initial escrow deposit -0-.  No cushion has been collected at closing.

Reviewer Comment (2016-12-07): No violation.  Escrow account is validly set up.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201109652

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00. (7505)

A lender credit has been issued at closing in the amount of ($310.65) which is sufficient to cure the under disclosure of the desk review of $150.00 and the under disclosure of the transfer tax of $1.65.

Reviewer Comment (2016-12-05): Cured at closing.

12/05/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201109652

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $2,557.65 exceeds tolerance of $2,556.00. (8304)

A lender credit has been issued at closing in the amount of ($310.65) which is sufficient to cure the under disclosure of the desk review of $150.00 and the under disclosure of the transfer tax of $1.65.

Reviewer Comment (2016-12-05): Cured at closing.

12/05/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201109652

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Missing secondary valuation.

Reviewer Comment (2016-12-16): Missing doc should be a credit exception, not compliance.  Exception reset as Credit.

12/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201109652

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

26% DTI on this full documentation loan < 50% guideline max - 24% below program guideline maximum

Reviewer Comment (2016-12-16): Client elects to waive.

12/16/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201109653

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.41930% or Final Disclosure APR of 8.42500% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201109653

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2016-12-13): File switched to Non-QM

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201109653

Compliance

Compliance

Federal Compliance

QM Points and Fees

Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of 4.09739% is in excess of the allowable maximum of  3.00000% of the Federal Total Loan Amount. Points and Fees total $19,775.40 on a Federal Total Loan Amount of $482,633.92 vs. an allowable total of $14,479.01 (an overage of $5,296.39 or 1.09739%).

Reviewer Comment (2016-12-13): File switched to Non-QM

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

If a creditor or assignee determines after consummation that the total points and fees exceeds the 3% limit, but the loan meets the other requirements to be a QM, the excess amount can be refunded with the following conditions: 1) The refund is made within 210 days of consummation; 2) The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit; 3) The loan is not 60 days delinquent; 4) The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments). The lender will also be required to provide a copy of the refund check and proof of delivery.

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201109653

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

31% DTI on this full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

Non QM

Non QM

No

C

B

201109654

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Lender

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the required  Lender Contact Information (Lender Name, Lender NMLS ID, Contact Name, Contact NMLS ID). (Final/[MM/DD/YYYY])

Lenders Contact NMLS ID is blank.

Reviewer Comment (2016-12-07): Lender contact is a CS Rep and doesn't have a unique identifier.

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201109654

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-07): Data correct on subsequent CDs (SFIG).

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201109654

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201109654

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.63850% or Final Disclosure APR of 8.63900% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201109654

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

605 > required 580.

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201109655

Compliance

Compliance

Miscellaneous Compliance

QM ATR Employment History

Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.

Borrower returned to work after an extended absence from and has not been employed by current employer for at least 6 months.

Reviewer Comment (2016-12-07): File switched to Non-QM

12/07/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201109655

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2016-12-07): File switched to Non-QM

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201109655

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $14,578.50, while closing CD seller's fees total $13,160.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109655

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.88570% or Final Disclosure APR of 7.88600% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201109655

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

26% DTI on this full documentation loan < 50% guideline max - 24% below program guideline maximum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201109656

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.69800% or Final Disclosure APR of 6.69800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201109656

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $17,015.86, while closing CD seller's fees total $10,235.86.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109656

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

723 representative FICO score > 620 guideline minimum - 103 points above guideline minimum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201109657

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Missing Secondary Valuation

Borrower on this loan has a disposable income of $5463.93

Reviewer Comment (2016-12-06): Client elects to waive.

12/06/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201109657

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109657

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201109657

Compliance

Compliance

Federal Compliance

TRID - Ten Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $671.50 exceeds tolerance of $603.00 plus 10% or $663.30 (0)

Reviewer Comment (2017-01-12): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201109657

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

$2 cure not sufficient for violation.

Reviewer Comment (2017-01-12): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201109657

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.14320% or Final Disclosure APR of 8.14300% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201109658

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.60980% or Final Disclosure APR of 8.61000% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

CD in file with an issue date of  is missing all documentation required for testing.  Loan term is blank as well as escrow information on page 4 and the loan calculation information on page 5.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

D

B

201109658

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $5893.28, while closing CD seller's fees total $14,376.78.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201109658

Compliance

Compliance

Federal Compliance

TRID - the file contains an illegible TRID disclosure. Testing is incomplete

Reviewer Comment (2016-12-06): Received attestation that disclosure was produced by title and never presented to borrower.

12/06/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

A

D

A

D

A

D

A

D

A

Higher Priced QM

Higher Priced QM

Yes

D

B

201109658

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Disclosure reflects Deposit = $0, however sales contract reflects that there was a deposit.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201109658

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Missing secondary valuation as required by guidelines.

25 months reserves > 3 months guideline minimum

Reviewer Comment (2016-12-02): Client elects to waive.

12/02/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

D

B

201110834

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.22980% or Final Disclosure APR of 9.22400% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

All fees are verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201110834

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/105076)

Monthly escrow for HOI of $59.67 does not reflect actual monthly amount of $59.75.

Reviewer Comment (2016-12-14): Data correct on subsequent CDs (SFIG).

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201110834

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/105076)

Monthly escrow for HOI of $59.67 does not reflect actual monthly amount of $59.75.

Reviewer Comment (2016-12-14): Data correct on subsequent CDs (SFIG).

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201110834

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Homeowners insurance premium is 716.96 per the policy provided.  Amount was collected properly in the prepaids, monthly / initial escrow payment should be calculated as 59.75 per month.  Final CD disclosed 59.67 per month.

Reviewer Comment (2016-12-14): Data correct on subsequent CDs (SFIG).

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201110834

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant.  Seller paid fees on Sellers Closing Disclosure are not consistent with those reflected on the Borrowers Final Closing Disclosure.  Sellers CD reflects $8,861.60 in seller paid fees.  Combined CD disclosed $12,680.01in seller paid fees.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201129323

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.28540% or Final Disclosure APR of 6.28500% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201129323

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.28540% or Final Disclosure APR of 6.28500% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201129323

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2016-12-07): Initial broker LE on different form, which is allowed.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201129323

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-20): Recalculation of 10% fees reflects no violation.  Cure provided at closing is sufficient. Reviewer Comment (2016-12-12): The issue isn't that the file funded on the 25th, the issue is the CD signed at closing reflects a funding date of the 23rd.  Disclosure need s to be corrected to reflect the correct funding date.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201129323

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,064.00 exceeds tolerance of $150.00 plus 10% or $165.00.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2016-12-20): Recalculation of 10% fees reflects no violation.  Cure provided at closing is sufficient.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201129323

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Payoff Statement Fee.  Fee Amount of $10.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75193)

Reviewer Comment (2016-12-20): Exception reset with "With Sufficient Cure" verbiage.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201129323

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $42.50 exceeds tolerance of $40.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-20): Exception reset with "With Sufficient Cure" verbiage.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201129323

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on [MM/DD/YYYY], prior to three (3) business days from transaction date of [MM/DD/YYYY].

Reviewer Comment (2016-12-20): Data correct on subsequent CDs (SFIG).

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201129323

Credit

Credit

Misc

Credit Exception:

DTI is over 50% at 53.4%.

Borrower on this full documentation loan has a disposable income of $5,255 when the required is $4,700. 3 months reserves required and we have 8 months verified. Max LTV is 80% and actual is 60%. Housing payments verified from 2006 and there have been no lates since 2011.

Reviewer Comment (2016-12-07): Client elects to waive.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201129323

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Payoff Statement Fee.  Fee Amount of $10.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75193)

Reviewer Comment (2016-12-20): Cured at closing

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201129323

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $42.50 exceeds tolerance of $40.00.  Sufficient or excess cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-20): Cured at closing

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201129324

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

42% DTI on this full documentation loan < 50% guideline max - 8% below program guideline maximum

Reviewer Comment (2016-12-07): Client elects to waive.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201129324

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-12): Received evidence that borrower received disclosure within timing requirements.

12/12/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201129324

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 2 that does not match the actual total payment for the loan. (ProjSeq:2/105383)

Calculated Estimated Total Monthly Payment is $1372.00

Reviewer Comment (2016-12-21): Data correct on subsequent CDs (SFIG).

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201129324

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 3 that does not match the actual total payment for the loan. (ProjSeq:3/105384)

Calculated Estimated Total Monthly Payment is $1372.00

Reviewer Comment (2016-12-21): Data correct on subsequent CDs (SFIG).

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201129324

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 4 that does not match the actual total payment for the loan. (ProjSeq:4/105385)

Calculated Estimated Total Monthly Payment is $1372.00

Reviewer Comment (2016-12-21): Data correct on subsequent CDs (SFIG).

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201129324

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201129324

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $575.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower. (7506)

Cure provided on Closing Disclosure

Reviewer Comment (2016-12-07): Cured at closing.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201129324

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $48.28 exceeds tolerance of $30.00.  Sufficient or excess cure was provided to the borrower. (7520)

Cure provided on Closing Disclosure

Reviewer Comment (2016-12-07): Cured at closing.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201129324

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Debt service months discrepancy.

Reviewer Comment (2016-12-15): Testing should have been done to PITI, not Debt Service amount.  No violation.

12/15/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201129326

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.71610% or Final Disclosure APR of 6.71600% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201129326

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.71610% or Final Disclosure APR of 6.71600% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201129326

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-14): Cured at closing.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201129326

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Reviewer Comment (2016-12-14): Valid CoC provided for fee.  No violation.

12/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201129326

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $192.00 exceeds tolerance of $50.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-14): Cured at closing.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201129326

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Employment Fee.  Fee Amount of $73.90 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7571)

Reviewer Comment (2016-12-14): Cured at closing.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201129326

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,182.50 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

Reviewer Comment (2016-12-14): Transfer tax is a seller paid fee in CA.  No violation

12/14/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201130831

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201130831

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.88490% or Final Disclosure APR of 8.88800% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201130831

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Total insurance premium is 3504, however, borrower had paid partial prior and paid balance of 2920 at closing

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201130831

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

only one appraisal in file

22 months reserves > 3 months guideline minimum

Reviewer Comment (2016-12-09): Client elects to waive.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201130832

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

36% DTI on this full documentation loan < 50% guideline max - 14% below program guideline maximum

Reviewer Comment (2016-12-08): Client elects to waive.

12/08/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201131083

Credit

Credit

Misc

Credit Exception:

LTV of 80% requires FICO score of 620 and borrower has a FICO score of 602.

Residual income of $4,061.20 when requirement is $1,350. 6 months reserves > 3 months guideline minimum.

Reviewer Comment (2016-12-08): Client elects to waive.

12/08/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201131084

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Caliber exception request and approval in file.  See .  However approval is for DTI of 47.763%, not 52.625%

Exception is for DTI in excess of 43% guideline.  Guideline variance approved by lender at time of origination.  Comp factors:  (1) Residual income $2,229 in excess of guideline  requirement of $800; (2) Reserves of 230 months  in excess of guideline requirement of 6 months; (3) Retirement income received over 2 years - meets two year employment history requirement; (4) FICO 728 in excess of guideline requirement of 660.  See page 104 in file.

Reviewer Comment (2016-12-13): Received updated lender exception reflecting higher DTI.  Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201131084

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.88680% or Final Disclosure APR of 6.88700% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201131084

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2016-12-13): All guideline violations have been addressed by lender.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201131084

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2016-12-13): All guideline violations have been addressed by lender.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201131084

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201131085

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this full documentation loan has a disposable income of $7638 43 months reserves > 3 months guideline minimum

Reviewer Comment (2016-12-09): Client elects to waive.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201131085

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.23460% or Final Disclosure APR of 8.23500% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201131085

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201131085

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.23460% or Final Disclosure APR of 8.23500% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201131085

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Borrower on this full documentation loan has a disposable income of $7638 43 months reserves > 3 months guideline minimum

Reviewer Comment (2016-12-09): Client elects to waive.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201131086

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.66830% or Final Disclosure APR of 6.66800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201131086

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.66830% or Final Disclosure APR of 6.66800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201131086

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-13): Received evidence that borrower received disclosure within timing requirements.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201131086

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2016-12-13): Received evidence that borrower received disclosure within timing requirements.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201131086

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

31% DTI on this full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2016-12-09): Client elects to waive.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201131086

Compliance

Compliance

Federal Compliance

RESPA Servicing Disclosure:  Servicing Disclosure Statement Not Provided Within 3 Business Days of Application

RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Statement to applicant within three (3) business days of application.

Box not checked off on initial LE.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201131086

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Servicing Missing

TILA-RESPA Integrated Disclosure - Other Considerations: Loan Estimate provided on [MM/DD/YYYY] did not disclose the Servicing statement. (Initial/[MM/DD/YYYY])

Box not checked off on disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201131086

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,779.50 exceeds tolerance of $884.00 plus 10% or $972.40.  Sufficient or excess cure was provided to the borrower. (0)

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201131087

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly amount reflects $155.03, however prepaid homeowner's insurance reflects $1885.34, should be $1860.36.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201131087

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-12): Data correct on subsequent CDs (SFIG).

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201131087

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation as required by guidelines.

21.55 months reserves > 3 months guideline minimum - borrowers have verified reserves of $119,155.50 44 month primary residence payment history verified on credit report when only 24 months required.

Reviewer Comment (2016-12-09): Client elects to waive.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201131087

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Disposable income discrepancy.

Lender approved exception.

21.55 months reserves > 3 months guideline minimum - borrowers have verified reserves of $119,155.50 44 month primary residence payment history verified on credit report when only 24 months required.

Reviewer Comment (2016-12-09): Client elects to waive.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201132951

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.49370% or Final Disclosure APR of 8.50100% is in excess of allowable threshold of APOR 3.58% + 1.5%, or 5.08000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201132951

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-13): Received evidence that borrower received disclosure within timing requirements.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201132951

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201132951

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201132951

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201132951

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $3,585.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Change of Circumstance provided for this increase does not list the discount fee as being affected.

Reviewer Comment (2016-12-19): Received VCC that references discount point.  No violation.

12/19/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201132952

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Post Close CD reflects Seller paid fees, however Seller's CD reflects $17,062.43 and Borrower's CD reflects $13,816.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201132952

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

Reviewer Comment (2016-12-09): Data was correxted on subsequent CDs.

12/09/2016

1

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

N/A

N/A

Yes

C

B

201132952

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

Administrative Fee changed to $995 Commitment Fee,

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201132952

Credit

Credit

Misc

Credit Exception:

Lender Approved Exceptions:    1).  Exception to use subject property income.  2).  Exception to require 12 months of housing expense payments for free and clear properties.

Borrower on this full documentation loan has a disposable income of $12038 Guideline variance approved by lender at time of origination.  14 months > 6 months required. 71% LTV < 80% guideline max

Reviewer Comment (2016-12-16): Client elects to waive.

12/16/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201132952

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-09): Final CD reflects $200 Lender Credit for tolerance cure.

12/09/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201132952

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75106)

Reviewer Comment (2016-12-09): Final CD reflects $200 Lender Credit for tolerance cure.

12/09/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201132953

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Payment Shock exceeds credit guidelines.

Lender approved exception.

12 months reserves > 3 months guideline minimum 70.163% LTV < 90 guideline max 47 months of rent history when only 24 months are required.

Reviewer Comment (2016-12-12): Client elects to waive.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201132953

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

12 months reserves > 3 months guideline minimum 70.163% LTV < 90 guideline max 47 months of rent history when only 24 months are required.

Reviewer Comment (2016-12-12): Client elects to waive.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201132953

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

12 months reserves > 3 months guideline minimum 70.163% LTV < 90 guideline max 47 months of rent history when only 24 months are required.

Reviewer Comment (2016-12-12): Client elects to waive.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201132953

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201132953

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.90970% or Final Disclosure APR of 5.91000% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201132953

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.90970% or Final Disclosure APR of 5.91000% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201132953

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $42,932.51, while closing CD seller's fees total $36,455.70.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201132953

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2016-12-12): Violation waived with Comp Factors.

12/12/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201132953

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2016-12-12): Violation waived with Comp Factors.

12/12/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201132954

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Collateral review was not provided.

40% DTI on this full documentation loan < 50% guideline max - 10% below program guideline maximum

Reviewer Comment (2016-12-09): Client elects to waive.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201132954

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.31290% or Final Disclosure APR of 8.31300% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201132954

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.31290% or Final Disclosure APR of 8.31300% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201132954

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

Reviewer Comment (2016-12-20): Data correct on subsequent CDs (SFIG).

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201132954

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

CD reflects $640, calculates to be $213.32. ($53.33 x 4 ).

Reviewer Comment (2016-12-20): Data correct on subsequent CDs (SFIG).

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201132954

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on 1[MM/DD/YYYY], prior to three (3) business days from transaction date of [MM/DD/YYYY].

Reviewer Comment (2016-12-20): Data correct on subsequent CDs (SFIG). Reviewer Comment (2016-12-13): Funding date per the final CD is [REDACTED].  This must be corrected in order to clear this exception.

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201132954

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,532.00 exceeds tolerance of $1,380.00 plus 10% or $1,518.00.  Sufficient or excess cure was provided to the borrower. (0)

$14.00 violation

Reviewer Comment (2016-12-09): Final CD reflects $14.00 Lender Credit for tolerance cure.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201132956

Credit

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

Appraisal report reflects Lender/Client as ". [REDACTED]. No transfer letter provided.

Reviewer Comment (2016-12-13): Received copy of transfer letter.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201132956

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

DTI Exception approved based on 1.) Residual income $9,400 vs $4,700 required, 2.) 13 months of PITI reserves vs 6 months required, 3.) LTV is 5% below program maximum.

Reviewer Comment (2016-12-09): Client elects to waive.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201132956

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.11580% or Final Disclosure APR of 6.11800% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

Tape data validated.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201132956

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.11580% or Final Disclosure APR of 6.11800% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Loan.

Tape data validated.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

No

C

B

201132956

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $57,327.86, Final CD shows $57,213.86

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201132956

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Higher Priced QM

Non QM

No

C

B

201132956

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

A

A

A

A

A

Higher Priced QM

Non QM

Yes

C

B

201132956

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

QM qualification requires the use of the maximum rate in the first 5 years method.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201132956

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201133858

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.99590% or Final Disclosure APR of 6.99600% is in excess of allowable threshold of APOR 3.27% + 2.5%, or 5.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201133858

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-10): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133858

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-3,494.00. (9300)

Lender credit on the last LE dated [MM/DD/YYYY] is -$3,494.00 at time of rate lock.

Reviewer Comment (2017-01-10): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133858

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $15,552.76, final CD shows $15,500.99.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133858

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $245.78 exceeds tolerance of $222.00 plus 10% or $244.20.  Insufficient or no cure was provided to the borrower. (0)

Final LE shows $222.00 and final CD shows $245.78. Violation amount is $1.58.

Reviewer Comment (2016-12-21): Cured at closing.

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133858

Credit

Credit

Misc

Credit Exception:

Housing Event Seasoning. Short sale was  and 2 years seasoning was required. Lender approved using the subject closing date for seasoning of as opposed to application date of .

Residual Income: $4,610 required, actual $7,210.07, excess of $2,600.07 per month. Transaction requires 9 months reserves of $36,313. Borrowers have verified post closing liquid assets of $119,497 covering an additional 29 months of subject PITIA (38 months total) While the DTI is not substantially under 43%, it is noted to be at 39.69%.

Reviewer Comment (2016-12-14): Client elects to waive.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201133858

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual Income: $4,610 required, actual $7,210.07, excess of $2,600.07 per month. Transaction requires 9 months reserves of $36,313. Borrowers have verified post closing liquid assets of $119,497 covering an additional 29 months of subject PITIA (38 months total) While the DTI is not substantially under 43%, it is noted to be at 39.69%.

Reviewer Comment (2016-12-14): Client elects to waive.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201133858

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $1,164.82 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Loan was locked on 11/18 with a corresponding LE issued.  Discount point was added on 11/23 without any change in loan details to warrant the addition of discount point.

Reviewer Comment (2017-01-10): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133859

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

Difference in APR of .31% from 11/22 CD to 11/29 CD and loan went from Fixed to ARM.

Reviewer Comment (2016-12-13): Received 11/ CD reflecting higher APR.  Timing requirements have been met.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201133859

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-12-13): Received evidence that borrower received disclosure within timing requirements.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201133859

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

29% DTI on this full documentation loan < 43% guideline max - 14% below program guideline maximum

Reviewer Comment (2016-12-12): Client elects to waive.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201133859

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $17,626.73, while closing CD seller's fees total $17,426.73.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133860

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee was charged for CDA but no report was provided.

23% DTI on this full documentation loan < 50% guideline max - 27% below program guideline maximum

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201133860

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.33900% or Final Disclosure APR of 8.33900% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201133860

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.33900% or Final Disclosure APR of 8.33900% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201133860

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

Reviewer Comment (2017-01-09): Data correct on subsequent CDs (SFIG).

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201133860

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $168.  Cure for $150 Collateral  Desktop Analysis fees and 10% tolerance violation of $18 was not provided.

Reviewer Comment (2017-01-09): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133860

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $150.00 exceeds tolerance of $120.00 plus 10% or $132.00.  Insufficient or no cure was provided to the borrower. (0)

$18.00 Violation due to increase in recording fees.

Reviewer Comment (2017-01-09): Received evidence that recording fee was actually $111 so no violation.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133860

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee not disclosed on LE dated[MM/DD/YYYY] and never referred to in CoCs.

Reviewer Comment (2017-01-09): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133861

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

37% DTI on this full documentation loan < 50% guideline max - 13% below program guideline maximum

Reviewer Comment (2016-12-13): Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201133861

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.04780% or Final Disclosure APR of 7.04800% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201133861

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/107086)

Lender based Hazard Insurance premium amount from insurance quote using $1,662.00 for calculations. Final binder shows $1,518.19 premium amount.

Reviewer Comment (2017-01-04): Data correct on subsequent CDs (SFIG).

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133861

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/107087)

Lender based Hazard Insurance premium amount from insurance quote using $1,662.00 for calculations. Final binder shows $1,518.19 premium amount.

Reviewer Comment (2017-01-04): Data correct on subsequent CDs (SFIG).

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133861

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/107088)

Lender based Hazard Insurance premium amount from insurance quote using $1,662.00 for calculations. Final binder shows $1,518.19 premium amount.

Reviewer Comment (2017-01-04): Data correct on subsequent CDs (SFIG).

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133861

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/107089)

Lender based Hazard Insurance premium amount from insurance quote using $1,662.00 for calculations. Final binder shows $1,518.19 premium amount.

Reviewer Comment (2017-01-04): Data correct on subsequent CDs (SFIG).

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133861

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/107086)

Lender based Hazard Insurance premium amount from insurance quote using $1,662.00 for calculations. Final binder shows $1,518.19 premium amount.

Reviewer Comment (2017-01-04): Data correct on subsequent CDs (SFIG).

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133861

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $15,088.15, final CD shows $17,669.30.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201133861

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-12-16): Received evidence that borrower received disclosure within timing requirements.

12/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201133861

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower. (7580)

Reviewer Comment (2016-12-13): Cured at closing.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201133862

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Hazard insurance amount of $ is not adequate, due to loan amount being $. Imaged file does not contain documentation from the property insurer to establish their opinion of the property's true replacement cost in order to determine if the amount of coverage is sufficient.

Reviewer Comment (2016-12-16): Dwelling replacement cost is covered by HOI coverage.

12/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201133862

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.91720% or Final Disclosure APR of 8.92400% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201133862

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

Prepaid Interest was disclosed as ($63.05) per day for (1) days for a total of  ($62.17), however this would equate to total paid of ($63.05).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133862

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $22,707.80, while closing CD seller's fees total $20,042.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133863

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $544.05, calculates to be $6735.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201133863

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-6,068.00. (9300)

LE dated [MM/DD/YYYY] reflects $6068 Lender Credit.  Final CD reflects $0.00.  Valid Changed Circumstance not found in file to justify this decrease in Lender Credit.

Reviewer Comment (2017-01-13): Credit moved from page 3 to page 1 and 2.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133863

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved Exception from 45% to 50% on 90% LTV/CLTV.

Borrower on this (Full) documentation loan has a disposable income of $7,541.25 745 representative FICO score > 680 guideline minimum 26 months reserves9 months guideline minimum

Reviewer Comment (2016-12-13): Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201133863

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2016-12-13): All guidelines violations have been addressed by lender.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201133863

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Lender approved DTI > 43%.

Reviewer Comment (2016-12-13): All guidelines violations have been addressed by lender.

12/13/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201133863

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant:  Missing payee for Processing fee, CD reflects paid to 3rd party.

Reviewer Comment (2017-01-13): Data correct on subsequent CDs (SFIG).

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133863

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD reflects $61,417. Borrower's CD reflects 74,544.41.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201133863

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,873.00 exceeds tolerance of $2,005.00 plus 10% or $2,205.50.  Insufficient or no cure was provided to the borrower. (0)

$667.50 violation

Reviewer Comment (2017-01-13): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133865

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

40% DTI on this full documentation loan < 50% guideline max - 10% below program guideline maximum

Reviewer Comment (2016-12-13): Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201133865

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.12420% or Final Disclosure APR of 9.20500% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

HPML verified to lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201133865

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

The final CD does not identify any seller paid fees. The post funding CD shows $4,000.00 in seller paid fees while the seller's CD shows $13,966.81.

Reviewer Comment (2017-01-09): Data supplied on subsequent CDs (SFIG).

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201133866

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.24780% or Final Disclosure APR of 6.24800% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201133866

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $15,079.00, final CD shows $19,865.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201133866

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-09): This is cured at settlement

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201133866

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

32% DTI on this full documentation loan < 50% guideline max - 18% below program guideline maximum

Reviewer Comment (2016-12-13): Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201133866

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Closing Protection Letter, Lender's Title Insurance and Title Examination fees reflected in section B, should be in section C.  Providers used are not listed on the SSPL.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201133867

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.70870% or Final Disclosure APR of 6.70900% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201133867

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $21,740.00, while closing CD seller's fees total $296,609.12.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201133867

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

718 > 680 required.

Reviewer Comment (2016-12-12): Client elects to waive.

12/12/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201133868

Credit

Loan Package Documentation

Application / Processing

Missing Document: Flood Certificate not provided

Flood Cert was not provided.

Reviewer Comment (2016-12-16): Received copy of Cert.

12/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201133868

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.49620% or Final Disclosure APR of 6.49600% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201133868

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7507)

Second appraisal fee was not disclosed on the Loan Estimate.

Reviewer Comment (2016-12-09): Cured at settlement.

12/09/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133868

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $171,568.14, final CD shows $136,915.50

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133868

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Lender Approved.

30.906% DTI on this full documentation loan < 50.00% guideline max - 19.1% below program guideline maximum Required Income: $10,000, Verified $39,753.75; excess of $29,753.75

Reviewer Comment (2016-12-13): Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201133868

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

30.906% DTI on this full documentation loan < 50.00% guideline max - 19.1% below program guideline maximum Required Income: $10,000, Verified $39,753.75; excess of $29,753.75

Reviewer Comment (2016-12-13): Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201133869

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

28% DTI on this full documentation loan < 50% guideline max - 22% below program guideline maximum

Reviewer Comment (2016-12-13): Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201133869

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201133869

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133870

Compliance

Compliance

Federal Compliance

Retirement Documentation

Qualified Mortgage (Dodd-Frank 2014): Retirement income documentation insufficient.

Pension Award Letter was not provided.

Reviewer Comment (2017-02-03): Received evidence of continuance. Reviewer Comment (2016-12-28): To meet Appendix Q requirements, proof of continuance for 3 years needs to be provided:  If any retirement income, such as employer pensions or 401(k)'s, will cease within the first full three years of the mortgage loan, such income may not be used in qualifying.

02/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201133870

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-03): Received evidence of continuance. Reviewer Comment (2017-01-05): Appendix Q requires proof of continuance for the next 3 years.

02/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201133870

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $41,589.00, Final CD shows $40,749.00.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133870

Property

Property - Appraisal

General Appraisal Requirements

HOA Information must be Yes on a Condo or PUD.

Appraisal indicated $0 HOA but Hazard and Flood insurance are paid by HOA. HOA cert was not provided. Review used HOA from 1003 for DTI calculations.

Reviewer Comment (2017-01-05): There is no HOA.  Gentleman's agreement that both are responsible for their own insurance.

01/05/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201133870

Credit

Loan Package Documentation

Application / Processing

Missing Document: HOA Questionnaire not provided

Reviewer Comment (2016-12-15): Received HOA Questionnaire.

12/15/2016

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201133870

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

Evidence provided is from closing.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201133870

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA (2010): Initial escrow account statement does not match charges on Final Closing Disclosure.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201133870

Credit

Credit

Misc

Credit Exception:

Assets - Use of 1031 exchange funds to purchase 2nd home. Lender exception approved.

34.028% LTV < 80.00% guideline max DTI can be at 50% and we are at 37.090% Only 3 months are required and we have over 24 months.

Reviewer Comment (2016-12-13): Client elects to waive.

12/13/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201133870

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/106920)

Escrow does not include HOI insurance.

Reviewer Comment (2017-02-24): Data correct on subsequent CDs (SFIG).

02/24/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133870

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/106921)

Escrow does not include HOI insurance.

Reviewer Comment (2017-02-24): Data correct on subsequent CDs (SFIG).

02/24/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133870

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/106922)

Escrow does not include HOI insurance.

Reviewer Comment (2017-02-24): Data correct on subsequent CDs (SFIG).

02/24/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133870

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/106923)

Escrow does not include HOI insurance.

Reviewer Comment (2017-02-24): Data correct on subsequent CDs (SFIG).

02/24/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201133870

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/106920)

Escrow does not include HOI insurance.

Reviewer Comment (2017-02-24): Data correct on subsequent CDs (SFIG).

02/24/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201136212

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

707 representative FICO score > 620 guideline minimum - 87 points above guideline minimum

Reviewer Comment (2016-12-14): Client elects to waive.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201136212

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.57480% or Final Disclosure APR of 6.57500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201136212

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Cure provided on Closing Disclosure

Reviewer Comment (2016-12-14): Final CD reflects $173 Lender Credit for tolerance cure.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136213

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender Approved 80% LTV with FICO of 586

Borrower on this documentation loan has a disposable income of $18,158.22 , which above required $4700. Borrower has employment stability for 20 years in the [REDACTED] Industry.

Reviewer Comment (2016-12-14): Client elects to waive.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $173, calculates to be $817.50.  Cure for $400 Appraisal, $85 Doc Prep, $25 Notary, $56.50 Abstract, $65 Attorney and $13 Wire fees was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $450.00 exceeds tolerance of $50.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee disclosed as $50 on LE dated 10/1/16 and as $450 on Final CD.

Reviewer Comment (2016-12-21): Re-review shows no violation for appraisal fee.

12/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search.  Fee Amount of $181.50 exceeds tolerance of $125.00.  Insufficent or no cure was provided to the borrower. (75178)

Fee disclosed as $125 on LE dated 10/1/16 and as $181.50 on Final CD

Reviewer Comment (2016-12-21): Fee moved to correct section.  No longer subject to tolerance testing.

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Attorney's Fee (Closing Agent Only).  Fee Amount of $565.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (75183)

Fee disclosed as $500 on LE dated 10/1/16 and as $565 on Final CD.

Reviewer Comment (2016-12-21): Fee moved to correct section.  No longer subject to tolerance testing.

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $13.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75206)

Fee not disclosed on LE

Reviewer Comment (2016-12-21): Fee moved to correct section.  No longer subject to tolerance testing.

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Document Preparation Fee.  Fee Amount of $85.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7563)

Fee not disclosed on LE

Reviewer Comment (2016-12-21): Fee moved to correct section.  No longer subject to tolerance testing.

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Notary Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7568)

Fee not disclosed on LE

Reviewer Comment (2016-12-21): Fee moved to correct section.  No longer subject to tolerance testing.

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $69.00.  Insufficent or no cure was provided to the borrower. (7580)

Fee disclosed as $69 on LE dated 10/1/16 and as $92 on Final CD.

Reviewer Comment (2016-12-14): Final CD reflects $173 Lender Credit for tolerance cure.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $59,409.66.  Borrower's CD reflects $122,152.32.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136213

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Foundation Title is not on SSPL but fees are listed in Section B.  This is the root of the majority of 0% tolerance violations.

Reviewer Comment (2016-12-21): Data correct on subsequent CDs (SFIG).

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136214

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status.

Reviewer Comment (2016-12-20): Received evidence that borrower received disclosure within timing requirements.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.16520% or Final Disclosure APR of 6.16500% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Non-Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

Reviewer Comment (2016-12-20): Received evidence that borrower received disclosure within timing requirements. Buyer Comment (2016-12-19): Please disregard upload this was uploaded to wrong file in error. [MM/DD/YYYY]

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

(Fed HPML Disclosure) Federal Higher-Priced Mortgage Loan (Right to Receive Cope of Appraisal)

TILA HPML Appraisal Rule (Dodd-Frank 2014):  Creditor did not provide "Right to Receive Copy" appraisal disclosure to consumer within three (3) business days of application.

App Date 10/27, Disclosure date 11/4.

Reviewer Comment (2016-12-20): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2016-12-20): There is no LE dated 11/1 in file or trailing documents.  Please provide initial application dated 11/1.  Earliest documents in file were issued 11/4.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.16520% or Final Disclosure APR of 6.16500% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136214

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Purchase Contract reflects $8k deposit required.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136214

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-22): Received evidence that borrower received disclosure within timing requirements.

12/22/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

A

A

A

A

A

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-12-19): Received evidence that borrower received disclosure within timing requirements.

12/19/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-12-19): Received evidence that borrower received disclosure within timing requirements.

12/19/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136214

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Lender Exception: Missing 2014 tax return, approved by lender.

Residual Income; Required $5050, actual residual income $5,909.06 Perfect 35 months of mortgage history.

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $39,622.14, final CD shows $3,740.00. .

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136214

Credit

Credit

Misc

Credit Exception:

Borrower has not been self employed for 2 years.  This would be allowed, however, borrower does not have a documented 2 year history in the same line of work prior to self employment.

Residual Income; Required $5050, actual residual income $5,909.06 Perfect 35 months of mortgage history.

Reviewer Comment (2017-01-03): Client elects to waive.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.16520% or Final Disclosure APR of 6.16500% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

Exception reset as a EV 1 and Compliant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201136214

Compliance

Compliance

Federal Compliance

RESPA Servicing Disclosure:  Servicing Disclosure Statement Not Provided Within 3 Business Days of Application

RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Statement to applicant within three (3) business days of application.

Reviewer Comment (2016-12-22): Received evidence that borrower received disclosure within timing requirements.

12/22/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201136215

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.20660% or Final Disclosure APR of 8.20700% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136215

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.20660% or Final Disclosure APR of 8.20700% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201136215

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-14): This was cured at settlement.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136215

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136215

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $36,098.80, final CD shows $314,449.73

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136215

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

35% LTV < 80% guideline max

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136216

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.73550% or Final Disclosure APR of 7.73500% is in excess of allowable threshold of APOR 4.12% + 1.5%, or 5.62000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201136216

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflectsd $23,059.23.  Borrower's CD reflects 23,183.73.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201136411

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.94220% or Final Disclosure APR of 6.94200% is in excess of allowable threshold of APOR 3.58% + 2.5%, or 6.08000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201136411

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.94220% or Final Disclosure APR of 6.94200% is in excess of allowable threshold of APOR 3.58% + 2.5%, or 6.08000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

B

B

201136411

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date 1[MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201136411

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $194.26 exceeds tolerance of $100.00.  Sufficient or excess cure was provided to the borrower. (7520)

Cure provided on Closing Disclosure

Reviewer Comment (2016-12-16): Cured at closing.

12/16/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201136411

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201136412

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

728 representative FICO score > 680 guideline minimum - 48 points above guideline minimum

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136412

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was (12/1/16).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136412

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.28660% or Final Disclosure APR of 7.28700% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136412

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $46,778.67.  Borrower's CD reflects $45,117.98.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136412

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Coverage $.  Estimated Cost New $.  Loan Amount $

Reviewer Comment (2016-12-19): Received evidence of insurance company's  replacement cost.  Coverage is sufficient.

12/19/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136413

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

30% LTV < 80% guideline max

Reviewer Comment (2016-12-16): Client elects to waive.

12/16/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136413

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $4,838.08, final CD shows $5,017.72.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136413

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 2933.  No tolerance violation of (transfer fee).  LE reflects transfer fee only, CD breaks down.  Per  can change VVC to yes, however system will not allow.

Reviewer Comment (2016-12-20): Transfer Fee paid by seller.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201136413

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,375.55 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

Erroneous Reg ID 3060.   LE reflects transfer fee only, CD breaks down.  Per [REDACTED] can change VVC to yes, however system will not allow.

Reviewer Comment (2016-12-20): Transfer Fee paid by seller.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201136414

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.15280% or Final Disclosure APR of 6.15300% is in excess of allowable threshold of APOR 3.27% + 2.5%, or 5.77000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136414

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.15280% or Final Disclosure APR of 6.15300% is in excess of allowable threshold of APOR 3.27% + 2.5%, or 5.77000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201136414

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136414

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $53.79 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-16): Lender provided credit at closing for the $53.79.

12/16/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136414

Credit

Credit

Misc

Credit Exception:

Lender Approved Exceptions:   1. The current DTI is 47.965% and cannot exceed 43%. 2. Realtor providing $ credit towards borrowers closing costs.

Residual income required is $5,650, actual $10,318 11 months reserves exceeds 9 months required

Reviewer Comment (2016-12-16): Client elects to waive.

12/16/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136415

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.52370% or Final Disclosure APR of 6.52400% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136415

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-12-16): Received evidence that borrower received disclosure within timing requirements.

12/16/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136415

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller 's CD reflects $3247.39.  Borrower's CD reflects $13,247.39.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136416

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

19% DTI on this full documentation loan < 50% guideline max - 31% below program guideline maximum

Reviewer Comment (2016-12-16): Client elects to waive.

12/16/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136416

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.32990% or Final Disclosure APR of 8.33000% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136416

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136416

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Survey Fee.  Fee Amount of $575.00 exceeds tolerance of $350.00.  Insufficent or no cure was provided to the borrower. (75203)

Fee was listed in Section B but vendor is not on SSPL.

Reviewer Comment (2016-12-23): Fee was moved to correct section, C.  No violation.

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136417

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.36920% or Final Disclosure APR of 8.38900% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201136417

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201136418

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

670 representative FICO score > 620 guideline minimum - 50 points above guideline minimum

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136418

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.59770% or Final Disclosure APR of 8.59800% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136419

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

26% DTI on this full documentation loan < 50% guideline max - 24% below program guideline maximum

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201136419

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201136419

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $21,930.08, final CD shows $21,929.56.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201136420

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.59800% or Final Disclosure APR of 8.59800% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136420

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.59800% or Final Disclosure APR of 8.59800% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201136420

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $26,636.40.  Borrower's CD reflects $16,503.75.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136420

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Lower LTV max is 70% LTV subject LTV is 40% 26 months reserves > 3 months required

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136420

Credit

Credit

Misc

Credit Exception:

Guideline required residual income is $1,200, actual residual income is $1,065.70.  Lender approved exception.

Lower LTV max is 70% LTV subject LTV is 40% 26 months reserves > 3 months required

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136421

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201136421

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

23% DTI on this full documentation loan < 50% guideline max - 27% below program guideline maximum

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201136422

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.81290% or Final Disclosure APR of 6.81300% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136422

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

Missing pages 5 & 6 of interim CD dated 1[MM/DD/YYYY].

Reviewer Comment (2016-12-21): Received complete copy of CD.

12/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136422

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136422

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income of $3,227.94 exceeds required of $1,200 Compensation or Income not reflected in effective income, borrower is part-time [REDACTED] at $1,000/monthly not being used to qualify.

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136422

Credit

Credit

Misc

Credit Exception:

RE Agent closing costs credit to borrower, total third party closing costs credit less than 6%.  Lender approved exception.

Residual income of $3,227.94 exceeds required of $1,200 Compensation or Income not reflected in effective income, borrower is part-time [REDACTED] at $1,000/monthly not being used to qualify.

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136422

Compliance

Compliance

Federal Compliance

TRID non-compliant:  There is a partially completed TRID disclosure in file, which is insufficient to complete testing.

Missing pages 5 & 6 of interim CD dated 1[MM/DD/YYYY].

Reviewer Comment (2016-12-21): Received complete copy of CD.

12/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201136423

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136423

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual Income of $3800 required.  Borrowers actual residual income is $5960. Cash reserves required of 9 mos.  Borrower has 20 mos. cash reserves. Primary housing history of 0x30x38 is significantly in excess of required 12 month pay history that program requires.

Reviewer Comment (2016-12-16): Client elects to waive.

12/16/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136423

Credit

Credit

Misc

Credit Exception:

1. Allow DTI of 51.34% when the max is 50%. 2. Allow use of gift funds for 2nd home purchase. Program allows for primary purchase only.

Residual Income of $3800 required.  Borrowers actual residual income is $5960. Cash reserves required of 9 mos.  Borrower has 20 mos. cash reserves. Primary housing history of 0x30x38 is significantly in excess of required 12 month pay history that program requires.

Reviewer Comment (2016-12-16): Client elects to waive.

12/16/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136423

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136423

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136423

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Pest Inspection Fee.  Fee Amount of $200.00 exceeds tolerance of $150.00.  Insufficent or no cure was provided to the borrower. (75155)

Pest Inspection fee was performed by a vendor that was no on SSPL however fee is being listed in Section B instead of Section C.

Reviewer Comment (2016-12-27): Fee moved to correct section and is no longer subject to

12/27/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136424

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of (1[MM/DD/YYYY]), but transaction consummation (mortgage notary) date was (1[MM/DD/YYYY]).   Data was not corrected on subsequent CD.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

B

B

201136424

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $237.00 exceeds tolerance of $119.00.  Sufficient or excess cure was provided to the borrower. (8304)

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

B

B

201136424

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Disclosure signed at closing references a previous waiver.  However, waiver not found in file.  Unable to determine if borrower waived their rights to receipt of appraisal 3 days prior to closing.  There was also no evidence that the copy of the appraisal was provided to the borrower at closing.  The disclosure states the report should have been provided, it does not state that it was provided to the borrower.

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

N/A

N/A

No

B

B

201136424

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $17,974.93.  Borrower's CD reflects $200,771.99.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

B

B

201136424

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,500.00 exceeds tolerance of $1,000.00.  Sufficient or excess cure was provided to the borrower. (7506)

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

B

B

201136425

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

33% DTI on this full documentation loan < 50% guideline max - 17% below program guideline maximum

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201136425

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.38400% or Final Disclosure APR of 6.38400% is in excess of allowable threshold of APOR 3.58% + 2.5%, or 6.08000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201136425

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-321.30  is less than amount of binding Lender Credit previously disclosed in the amount of $-327.00. (9300)

LE dated 1[MM/DD/YYYY] reflects $327 Lender Credit.  Final CD reflects $321.30.  Valid Changed Circumstance not found to justify this decrease in Lender credit.

Reviewer Comment (2016-12-21): Received VCC that addresses the change in lender credit.

12/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201136425

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $3046.  Borrower's CD reflects $13,079.14.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201136426

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

53 months reserves > 3 months guideline minimum

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201136426

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.25280% or Final Disclosure APR of 8.25200% is in excess of allowable threshold of APOR 3.58% + 1.5%, or 5.08000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201136426

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.25280% or Final Disclosure APR of 8.25200% is in excess of allowable threshold of APOR 3.58% + 1.5%, or 5.08000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201136426

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201136427

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.31440% or Final Disclosure APR of 8.31400% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201136427

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-19): Received evidence that borrower received disclosure within timing requirements.

12/19/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136427

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller fees disclosed on Final Closing Disclosure

Reviewer Comment (2016-12-27): Data correct on subsequent CDs (SFIG).

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136427

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-12-19): Received evidence that borrower received disclosure within timing requirements.

12/19/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136427

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income of $1,599 exceeds required of $600 LTV at 79% less than maximum of 85%

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136427

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual closing date is 1[MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136427

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,054.00 exceeds tolerance of $914.00 plus 10% or $1,005.40.  Sufficient or excess cure was provided to the borrower. (0)

Cure provided on Closing Disclosure

Reviewer Comment (2016-12-14): Lender cured on final CD with a $52.85 tolerance cure.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136427

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $29.25 exceeds tolerance of $25.00.  Sufficient or excess cure was provided to the borrower. (7520)

Cure provided on Closing Disclosure

Reviewer Comment (2016-12-14): Lender cured on final CD with a $52.85 tolerance cure.

12/14/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136427

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

Residual income of $1,599 exceeds required of $600 LTV at 79% less than maximum of 85%

Reviewer Comment (2016-12-15): Client elects to waive.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201136427

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2016-12-19): All guidelines violations have been addressed by lender.

12/19/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201136427

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2016-12-19): All guidelines violations have been addressed by lender.

12/19/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201136428

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date 1[MM/DD/YYYY]

Reviewer Comment (2016-12-23): Data correct on subsequent CDs (SFIG).

12/23/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201136428

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201136428

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on 1[MM/DD/YYYY], prior to three (3) business days from transaction date of 1[MM/DD/YYYY].

Reviewer Comment (2016-12-23): Data correct on subsequent CDs (SFIG). Buyer Comment (2016-12-22): Finally received corrected CD, and has now been uploaded to you portal and should clear this suspense. Reviewer Comment (2016-12-16): This is in regards to the disbursement date reflected on the final CD.  Once that is corrected, this exception will be cleared.

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136428

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Lender reflected a tolerance cure of $165; however, this cures only the tolerance violations for the appraisal update and appraisal fee.  The $2 required for the tax service fee tolerance violation was not provided.

Reviewer Comment (2016-12-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201136428

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $500.00 exceeds tolerance of $485.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-15): Lender cured on final CD with $165 tolerance cure.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136428

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75103)

Reviewer Comment (2016-12-15): Lender cured on final CD with $165 tolerance cure.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136428

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Initial GFE reflects fee as $90, final CD at $92, no valid COC found in the file for the increase in fee and cure provided on final CD is insufficient to cure this tolerance.

Reviewer Comment (2016-12-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201136428

Credit

Credit

Misc

Credit Exception:

Required residual income $7,880, actual residual income $7,599.  Lender approved exception.

3 months reserves required.  Borrower has 67 months. Subject property mortgage history 0x30x82 versus required 0x30x24 Borrower's mortgage payment decreased by $554.28 per month

Reviewer Comment (2016-12-15): Required residual income $7,880, actual residual income $7,599.  Lender approved exception.

12/15/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

Non QM

Non QM

No

C

B

201136429

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower:

Missing VOE for all employments and 1065 income source.

Reviewer Comment (2017-01-18): Received required income documentation. Reviewer Comment (2017-01-05): 1065 is negative and VVOE not required.  All wage sources still missing VVOEs within 10 days of note.

01/18/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

C

A

C

A

C

A

C

A

C

A

Exempt from ATR

N/A

No

C

B

201136429

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

C

B

201136429

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 1[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-01-05): Received evidence that borrower received disclosure within timing requirements.

01/05/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Exempt from ATR

N/A

No

C

B

201136429

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $570.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-15): Cured at settlement.

12/15/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

C

B

201136429

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75106)

Reviewer Comment (2016-12-15): Cured at settlement.

12/15/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

C

B

201136429

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $18.00.  Sufficient or excess cure was provided to the borrower. (7580)

Reviewer Comment (2016-12-15): Cured at settlement.

12/15/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

C

B

201138015

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

758 representative FICO score > 680 guideline minimum - 78 points above guideline minimum

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138015

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.20220% or Final Disclosure APR of 6.23000% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201138015

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.20220% or Final Disclosure APR of 6.23000% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201138015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a negative fee amount. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138015

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-02-01): Received evidence that borrower received disclosure within timing requirements.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201138016

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

55% LTV < 80% guideline max

Reviewer Comment (2016-12-22): Client elects to waive.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138016

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201138233

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

797 representative FICO score > 660 guideline minimum - 137 points above guideline minimum

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138233

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.96010% or Final Disclosure APR of 5.96000% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201138233

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138233

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138233

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.96010% or Final Disclosure APR of 5.96000% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201138233

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138233

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-593.00. (9300)

Reviewer Comment (2017-01-03): VCC regarding lender credit reduction received.

01/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201138233

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

COC provided indicates lock extended which would not be a valid COC for an increase in appraisal fee.

Reviewer Comment (2017-01-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201138234

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2016-12-19): Lender cured with initial CD reflecting No Seller Table and subsequent CD's.

12/19/2016

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138234

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

54 months reserves > 6 months guideline minimum - borrowers have verified reserves of $227995.45 Borrower on this  loan has a disposable income of $6,344.34

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138234

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

54 months reserves > 6 months guideline minimum - borrowers have verified reserves of $227995.45 Borrower on this  loan has a disposable income of $6,344.34

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138234

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2016-12-19): All guidelines violations have been addressed by lender.

12/19/2016

1

[REDACTED]

[REDACTED]

Second Home

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201138234

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2016-12-19): All guidelines violations have been addressed by lender.

12/19/2016

1

[REDACTED]

[REDACTED]

Second Home

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201138234

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $134.36 exceeds tolerance of $100.00.  Sufficient or excess cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-19): Cured at closing.

12/19/2016

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138235

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.55470% or Final Disclosure APR of 8.59100% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201138235

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-21): Received evidence that borrower received disclosure within timing requirements.

12/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201138235

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-10): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138235

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138235

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $54.00 exceeds tolerance of $45.00 plus 10% or $49.50.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2017-01-10): Received copy of check, corrected CD, proof of delivery and LOE to borrower for borrower's portion of recording fee violation.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201138235

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $42.10 exceeds tolerance of $35.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-19): Lender cured on final CD with a $9.10 tolerance cure.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201138235

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2016-12-19): Lender cured on final CD with a $9.10 tolerance cure.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201138236

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income of $1,927 exceeds guideline requirement of $1,300 Reserves of 14 months exceeds required of 3 months Housing history of 0x30x43 exceeds required of 0x30x12

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138236

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account Statement Missing

RESPA (2010): Initial escrow account statement was not provided to the borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201138236

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Maximum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment (Maximum) for payment stream 2 that does not match the actual total payment for the loan. (ProjSeq:2/109890)

Payment amount not accurately rounded.

Reviewer Comment (2017-02-08): Data correct on subsequent CDs (SFIG).

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201138236

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Maximum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment (Maximum) for payment stream 4 that does not match the actual total payment for the loan. (ProjSeq:4/109892)

Payment amount not accurately rounded.

Reviewer Comment (2017-02-08): Data correct on subsequent CDs (SFIG).

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201138236

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138236

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.98250% or Final Disclosure APR of 6.99400% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201138236

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

Residual income of $1,927 exceeds guideline requirement of $1,300 Reserves of 14 months exceeds required of 3 months Housing history of 0x30x43 exceeds required of 0x30x12

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138236

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2016-12-20): All guidelines violations have been addressed by lender.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201138236

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2016-12-20): All guidelines violations have been addressed by lender.

12/20/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201138237

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

28% DTI on this full documentation loan < 50% guideline max - 22% below program guideline maximum

Reviewer Comment (2016-12-19): Client elects to waive.

12/19/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138237

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.67420% or Final Disclosure APR of 6.64100% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201138237

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Security Instrument Notary date 1[MM/DD/YYYY], final CD reflects consummation date of 1[MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138237

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

It appears the lender did not include the Attorney fee of $1,500 in the finance charge.

Reviewer Comment (2016-12-28): Attorney Fee not required for closing therefor is not required to be counted in Finance Charge.

12/28/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201138237

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138237

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title agent not reflected on SSPL and title fees in section B versus section C.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138890

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

27 months reserves > 9 months guideline minimum

Reviewer Comment (2016-12-21): Client elects to waive.

12/21/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138890

Compliance

Compliance

Federal Compliance

Social Security Documentation

Qualified Mortgage (Dodd-Frank 2014): Social Security income documentation insufficient.

Award Letter not in file

Reviewer Comment (2017-01-09): File switched to Non-QM Reviewer Comment (2016-12-29): Received all Pension awards letters.  However, the exception is for SSI awards letter.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201138890

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.26160% or Final Disclosure APR of 6.26200% is in excess of allowable threshold of APOR 3.27% + 2.5%, or 5.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201138890

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-01-09): File switched to Non-QM

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201138890

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-23): Received evidence that borrower received disclosure within timing requirements.

12/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201138890

Credit

Credit

Misc

Credit Exception:

Per 1003, Lender used $680 for payment on what appears to be a 30 day account.  No evidence was provided to support this payment amount.  Using 5% rule, payment would be $1683.  Please provide documentation to support payment used by lender.  DTI subject to change.

Reviewer Comment (2016-12-23): Received evidence of monthly payment in line with lender's calculations.

12/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201138891

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income of $7,946.94 exceeds required of $2,700. 0x30x24 exceeds required of 0x30x12

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138891

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138891

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138891

Credit

Credit

Misc

Credit Exception:

Gift funds not allowed on second homes.  Lender approved exception.

Residual income of $7,946.94 exceeds required of $2,700. 0x30x24 exceeds required of 0x30x12

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138891

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title agent not reflected on SSPL and title fees incorrectly in section B versus C.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138892

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

39% DTI on this full documentation loan < 50% guideline max - 11% below program guideline maximum

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201138892

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.48570% or Final Disclosure APR of 6.48600% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201138892

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201138893

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-21): Received evidence that borrower received disclosure within timing requirements.

12/21/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201138893

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-28): Data correct on subsequent CDs (SFIG).

12/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201138893

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Calculated Total Interest Percentage is 132.649%

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201138893

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34% DTI on this full documentation loan < 50% guideline max - 16% below program guideline maximum

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201138894

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.34040% or Final Disclosure APR of 7.34000% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201138894

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-27): Received evidence that borrower received disclosure within timing requirements.

12/27/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201138894

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201138894

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201138894

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75103)

Change of Circumstance or cure not provided

Reviewer Comment (2017-01-11): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2016-12-27): Unable to determine how upload addresses 0% tolerance violation.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201138894

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this full documentation loan has a disposable income of $9825.25 30.47% DTI on this  full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2016-12-22): Client elects to waive.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201138894

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Borrower on this full documentation loan has a disposable income of $9825.25 30.47% DTI on this  full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2016-12-22): Client elects to waive.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201138895

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

710 > required 680

Reviewer Comment (2016-12-22): Client elects to waive.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138895

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.03140% or Final Disclosure APR of 7.03100% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201138895

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

CD issued 12/7 and signed by borrower does not reflect a product.

Reviewer Comment (2017-02-17): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2016-12-29): Lender states that CD in question wasn't supplied to borrower.  However, CD issued 12/7 that has the product missing was signed by borrower.  Even if it's title issued CD, it was presented to borrower and thus becomes a valid disclosure.

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201138895

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201138896

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

45 months reserves > 6 months guideline minimum

Reviewer Comment (2016-12-22): Client elects to waive.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201138896

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.01500% or Final Disclosure APR of 8.02000% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201138896

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201138896

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Total Closing Costs did not exceed the legal limit

Reviewer Comment (2016-12-23): No cure needed.

12/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201138896

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,436.20 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

No violation - Transfer Tax paid by Seller

Reviewer Comment (2016-12-23): No violation.  Seller paid fee.

12/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201138897

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201138897

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-27): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2016-12-22): Received LOE stating 9/13 LE was received by borrower.  However, no LE issued on 9/13 was located in file.  Please provide 9/13 LE.

12/27/2016

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201138897

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201138897

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201138897

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this full documentation loan has a disposable income of $15301.96 34 months reserves > 6 months guideline minimum - borrowers have verified reserves of $55502.53 24.94% DTI on this full documentation loan < 43% guideline max - 18.06% below program guideline maximum

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201138897

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Due to Non-Warrantable Condo Level 3 restrictions.  Lender approved exception.

Borrower on this full documentation loan has a disposable income of $15301.96 34 months reserves > 6 months guideline minimum - borrowers have verified reserves of $55502.53 24.94% DTI on this full documentation loan < 43% guideline max - 18.06% below program guideline maximum

Reviewer Comment (2016-12-20): Client elects to waive.

12/20/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201138897

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $90.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-20): Lender cured on final CD with a $90.20 tolerance cure.

12/20/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201138897

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $232.00 exceeds tolerance of $150.00 plus 10% or $165.00.  Insufficient or no cure was provided to the borrower. (0)

Per 9/13 LE, fee was listed as $150 and final shows $232.00.  No VCC found that mentions the increase in fee.

Reviewer Comment (2017-01-19): Received attestation from title that seller paid recording fees are for reconveyance and termination of UCC, which are seller responsible fees. Reviewer Comment (2017-01-12): Unable to locate evidence that there is no 10% violation.  Per purchase contract, buyer is to pay all recording fees.  Even though part is seller paid, this is traditionally a buyer paid fee and must be thoroughly disclosed to buyer.

01/19/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201138897

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $500.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7506)

Per 9/13 LE, no appraisal fee was listed.  Final shows $500.00.  No VCC found that mentions the increase in fee.

Reviewer Comment (2017-01-12): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/12/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201142081

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2016-12-30): Received insurance provided replacement cost showing coverage is sufficient.

12/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201142081

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.43640% or Final Disclosure APR of 6.43600% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201142081

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.43640% or Final Disclosure APR of 6.43600% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

No

C

B

201142081

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201142081

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201142081

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $550.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2017-01-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201142081

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Seller paid Escrow fee is in Section C when it should be in Section B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201142081

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

UW Notes reflect $k withdrawn from Co-borrower's IRA/Trust account but no evidence was provided.  UW Notes also reflect balances on accounts that are no longer valid due to more recent statements being provided.

Reviewer Comment (2017-01-24): IRA account added to calculations.

01/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201142081

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

UW Notes reflect k withdrawn from Co-borrower's IRA/Trust account but no evidence was provided.  UW Notes also reflect balances on accounts that are no longer valid due to more recent statements being provided.

Borrower on this full documentation loan has a disposable income of $8498.97

Reviewer Comment (2017-01-27): Client elects to allow IRA account for closing without proof of liquidation.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201142081

Compliance

Compliance

Federal Compliance

TIL HPML Safe-Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Higher Priced QM

Non QM

No

C

B

201142081

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

A

A

A

A

A

Higher Priced QM

Non QM

Yes

C

B

201142081

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

QM qualification requires the use of the maximum rate in the first 5 years method.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201142081

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201142082

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

27% DTI on this full documentation loan < 50% guideline max - 23% below program guideline maximum

Reviewer Comment (2016-12-22): Client elects to waive.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201142082

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.56600% or Final Disclosure APR of 7.56600% is in excess of allowable threshold of APOR 3.98% + 1.5%, or 5.48000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201142083

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/111631)

Unable to determine how escrow amount were calculated.  Per documents in file, HOI is $3262, but CD reflects $3276 and taxes are $22,415.88, but CD reflects $21,812.60.  Due to these discrepancies, escrow amount is not correct.

Reviewer Comment (2017-01-30): Data correct on subsequent CDs (SFIG). Reviewer Comment (2017-01-09): HOI updated, but taxes still do not reconcile.  Document sent in was for 2015 taxes and reflects $22,561.84.

01/30/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201142083

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/111631)

Unable to determine how escrow amount were calculated.  Per documents in file, HOI is $3262, but CD reflects $3276 and taxes are $22,415.88, but CD reflects $21,812.60.  Due to these discrepancies, escrow amount is not correct.

Reviewer Comment (2017-01-30): Data correct on subsequent CDs (SFIG). Reviewer Comment (2017-01-09): HOI updated, but taxes still do not reconcile.  Document sent in was for 2015 taxes and reflects $22,561.84.

01/30/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201142083

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142083

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $775.00 exceeds tolerance of $700.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-22): Cured at closing.

12/22/2016

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142083

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75106)

Reviewer Comment (2016-12-22): Cured at closing.

12/22/2016

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142083

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $78.54 exceeds tolerance of $65.00.  Sufficient or excess cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-22): Cured at closing.

12/22/2016

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142083

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Debt service months discrepancy.

Borrower on this loan has a disposable income of $8893.53

Reviewer Comment (2016-12-22): Client elects to waive.

12/22/2016

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201142084

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

54% LTV < 80% guideline max

Reviewer Comment (2016-12-22): Client elects to waive.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201142084

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $300.00 exceeds tolerance of $200.00.  Sufficient or excess cure was provided to the borrower. (75103)

Change of Circumstance provided

Reviewer Comment (2016-12-22): Cured at closing

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201142085

Compliance

Loan Package Documentation

Closing / Title

(Doc Error) Security Instrument Error: Notary/Security Instrument Date  was not provided

Reviewer Comment (2017-01-09): Received Correction Instrument for Notary listing actual notary date.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201142085

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved.

$231 monthly overtime income not used in qualifications. $2,589.72 residual income exceeds $1800 minimum requirement.

Reviewer Comment (2016-12-23): Client elects to waive.

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201142085

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

$231 monthly overtime income not used in qualifications. $2,589.72 residual income exceeds $1800 minimum requirement.

Reviewer Comment (2016-12-23): Client elects to waive.

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201142085

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.85450% or Final Disclosure APR of 7.86500% is in excess of allowable threshold of APOR 3.98% + 1.5%, or 5.48000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201142085

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2016-12-23): All guidelines violations have been addressed by lender.

12/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201142085

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2016-12-23): All guidelines violations have been addressed by lender.

12/23/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201142085

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $126.50.  Cure for $53 Title Insurance and $73.50 Endorsement fees was not provided.

Reviewer Comment (2017-01-09): Fee moved to correct section and no longer subject to 0% testing.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142085

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $8442.73.  Borrower's CD reflects $18,934.58.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142085

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $207.50 exceeds tolerance of $134.00.  Insufficent or no cure was provided to the borrower. (7564)

Fee disclosed as $134 on 11/1/16 and as $207.50 on Final CD.

Reviewer Comment (2017-01-09): Fee moved to correct section and no longer subject to 0% testing.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201142085

Credit

Credit

Misc

Credit Exception:

Missing verification of receipt for  FEMA Assistance.  Email from provider indicates funds to be given directly to the Title Company on ., however Final CD does not reflect these funds..

Reviewer Comment (2017-01-09): Received evidence of receipt.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201142085

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Settlement, Survey, Title Insurance and Endorsement fees reflected in section B, should be in section C.  Providers used not listed on SSPL.

Reviewer Comment (2017-01-09): Fee moved to correct section and no longer subject to 0% testing.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142085

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Lender's Title Insurance.  Fee Amount of $1,216.00 exceeds tolerance of $1,163.00.  Insufficent or no cure was provided to the borrower. (7567)

Fee disclosed as $1163 on LE dated 11/1/16 and as $1216 on Final CD.

Reviewer Comment (2017-01-09): Fee moved to correct section and no longer subject to 0% testing.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201142086

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

693 representative FICO score > 620 guideline minimum - 73 points above guideline minimum

Reviewer Comment (2016-12-28): Client elects to waive.

12/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201142086

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower:

Award/Continuation letter was not provided to establish continuance of 3 years of income.

693 representative FICO score > 620 guideline minimum - 73 points above guideline minimum Borrower on this full documentation loan has a disposable income of $4266

Reviewer Comment (2017-01-09): Client elect to waive. Reviewer Comment (2017-01-05): Per lender guidelines:  SSI: Award letter and evidence of receipt in bank account Reviewer Comment (2017-01-05): Lender states proof of continuance is not required.  Per guidelines:  Retirement Income: Account statement plus evidence of receipt in bank account and determination of continuance.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201142086

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's mortgage payoff was included in Section H, and Seller credit of $5,000 was applied directly to fees on page 2 instead of being listed on page 3.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142086

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.21580% or Final Disclosure APR of 7.21600% is in excess of allowable threshold of APOR 3.98% + 1.5%, or 5.48000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201142086

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142086

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Departing residence mortgage is an IO that is getting ready to adjust and become fully amortized.

693 representative FICO score > 620 guideline minimum - 73 points above guideline minimum Borrower on this full documentation loan has a disposable income of $4266

Reviewer Comment (2017-01-09): Client elect to waive. Reviewer Comment (2017-01-05): Lender states UW used $1035 for departing residence PI payment.  This number is not sufficient for when the loan fully amortizes over a 20 year term.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201142086

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

This is associated with DTI violation.

Reviewer Comment (2017-01-09): All guidelines violations have been addressed by lender.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201142086

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

This is associated with DTI violation.

Reviewer Comment (2017-01-09): All guidelines violations have been addressed by lender.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201142087

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201142087

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75106)

Reviewer Comment (2016-12-22): Cured at closing.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201142087

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,060.00 exceeds tolerance of $1,039.00.  Sufficient or excess cure was provided to the borrower. (8304)

Reviewer Comment (2016-12-22): Cured at closing.

12/22/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201142295

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Reviewer Comment (2017-01-03): Received reports done after disaster shows property is still standing.

01/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201142295

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.31770% or Final Disclosure APR of 6.31800% is in excess of allowable threshold of APOR 3.15% + 2.5%, or 5.65000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201142295

Compliance

Compliance

State Compliance

North Carolina Rate Spread Threshold Test

North Carolina Rate Spread Home Loan: APR on subject loan of 6.31770% or Final Disclosure APR of 6.31800% is in excess of allowable threshold of APOR 3.15% + 2.5%, or 5.65000%.  Compliant Rate Spread Home Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201142295

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-29): Received evidence that borrower received disclosure within timing requirements.

12/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201142295

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on 1[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-12-29): Received evidence that borrower received disclosure within timing requirements.

12/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201142295

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2016-12-29): Received evidence that borrower received disclosure within timing requirements.

12/29/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201142296

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.66030% or Final Disclosure APR of 7.71900% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201142296

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.66030% or Final Disclosure APR of 7.71900% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201142296

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $21,223.  Borrower's CD reflects $1,893.50

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201142296

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $534.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-23): Final CD reflects $220 Lender Credit for tolerance cure.

12/23/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201142296

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

39% DTI on this full documentation loan < 50% guideline max - 11% below program guideline maximum

Reviewer Comment (2016-12-27): Client elects to waive.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201142297

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

38% DTI on this full documentation loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2016-12-27): Client elects to waive.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Safe Harbor QM

Safe Harbor QM

No

C

B

201142297

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $58,243.61.  Borrower's CD reflects 53,288.07.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Safe Harbor QM

Safe Harbor QM

Yes

C

B

201142297

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2016-12-30): Designation switched to Safe Harbor QM.

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Safe Harbor QM

Safe Harbor QM

Yes

C

B

201142297

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2016-12-30): Received evidence that borrower received disclosure within timing requirements.

12/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Safe Harbor QM

Safe Harbor QM

No

C

B

201148466

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower has $98,948 in [REDACTED] and $21,683 in [REDACTED]. 19 mos reserves in excess of requirement of 6 months. Excellent housing payment history. 47 months of perfect pay history; program only requires 6 months. Borrowers have employment stability for 2 years with the same employers. Minimal mortgage payment increase by 7.764%. Residual income of $7,331 is above the minimum required amount of $3,100 for an excess of $4,231.

Reviewer Comment (2016-12-27): Client elects to waive.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201148466

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.65800% or Final Disclosure APR of 6.65800% is in excess of allowable threshold of APOR 3.98% + 1.5%, or 5.48000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201148466

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller at Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201148466

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201148466

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,675.00. (9300)

Reviewer Comment (2017-01-09): Credit was moved from page 3 to it's correct place on pages 1 and 2. Reviewer Comment (2017-01-04): Received corrected CD reflecting lender credit, but no refund check was provided.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201148466

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $775.00 exceeds tolerance of $575.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-27): Cured at closing.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201148466

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Lender's Title Insurance.  Fee Amount of $1,767.95 exceeds tolerance of $1,674.00.  Insufficent or no cure was provided to the borrower. (7567)

Fee is listed in Section B, but vendor is not on SSPL.

Reviewer Comment (2017-01-04): Fees moved to correct section and no longer part of 0% tolerance testing.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201148466

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower has $98,948 in [REDACTED] and $21,683 in [REDACTED]. 19 mos reserves in excess of requirement of 6 months. Excellent housing payment history. 47 months of perfect pay history; program only requires 6 months. Borrowers have employment stability for 2 years with the same employers. Minimal mortgage payment increase by 7.764%. Residual income of $7,331 is above the minimum required amount of $3,100 for an excess of $4,231.

Reviewer Comment (2016-12-27): Client elects to waive.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201148466

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2016-12-27): All guidelines violations have been addressed by lender.

12/27/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201148466

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2016-12-27): All guidelines violations have been addressed by lender.

12/27/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201148467

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Guideline variance approved by lender at time of origination. Borrower has no negative credit or housing events, meets traditional trade line requirements. Residual Income required $8,600, actual is $43,000, excess of $34,400. Reserves required are 9 months, verified liquid 17 months. DTI substantially below 43%, under 27%.

Reviewer Comment (2016-12-27): Client elects to waive.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201148467

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $850.00 exceeds tolerance of $700.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-27): Cured at closing

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201148468

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.82840% or Final Disclosure APR of 6.82800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201148468

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-18): Received correct\ed CoC along with explanation regarding program change that would require a CDA.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201148468

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee not listed on CoC.

Reviewer Comment (2017-01-18): Received correct\ed CoC along with explanation regarding program change that would require a CDA. Reviewer Comment (2017-01-06): Received original CoC with CDA fee added post close.  Adding a fee post close does not make it valid.  Exception remains.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201148468

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201148469

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.68330% or Final Disclosure APR of 6.68300% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201148469

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-30): Received evidence that borrower received disclosure within timing requirements.

12/30/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201148469

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Security Instrument executed on [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201148469

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201148470

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.27170% or Final Disclosure APR of 9.34300% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201148470

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 9.27170% or Final Disclosure APR of 9.34300% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201148470

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

37 months reserves > 6 months guideline minimum

Reviewer Comment (2016-12-27): Client elects to waive.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201148471

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Guideline variance approved by lender at time of origination. Program max LTV 70%. Exception for subject loan 80% LTV. Exception based on following compensating factors: Residual Income required is $800. Actual is $2,846.65. Cash reserves required 3 months. Estimated is 14 months.

Reviewer Comment (2016-12-27): Client elects to waive.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201148471

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.23870% or Final Disclosure APR of 9.23900% is in excess of allowable threshold of APOR 4.12% + 1.5%, or 5.62000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201148471

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201148471

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $92.04 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower. (7520)

Reviewer Comment (2016-12-27): Cured at closing.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201148472

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.84230% or Final Disclosure APR of 7.84200% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201148472

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201148472

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

41% DTI on this full documentation loan < 50% guideline max - 9% below program guideline maximum

Reviewer Comment (2016-12-27): Client elects to waive.

12/27/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201150240

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Reviewer Comment (2017-01-03): Received copy of Note.

01/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

D

A

D

A

D

A

D

A

D

A

Higher Priced QM

Higher Priced QM

No

D

B

201150240

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/113777)

Closing Disclosure is using the expired hazard insurance premiumof $1457. Updated policy in file has an increased amount of $1509.

Reviewer Comment (2017-01-12): Data correct on subsequent CDs (SFIG).

01/12/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201150240

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/113778)

Closing Disclosure is using the expired hazard insurance premiumof $1457. Updated policy in file has an increased amount of $1509.

Reviewer Comment (2017-01-12): Data correct on subsequent CDs (SFIG).

01/12/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201150240

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/113779)

Closing Disclosure is using the expired hazard insurance premiumof $1457. Updated policy in file has an increased amount of $1509.

Reviewer Comment (2017-01-12): Data correct on subsequent CDs (SFIG).

01/12/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201150240

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/113780)

Closing Disclosure is using the expired hazard insurance premiumof $1457. Updated policy in file has an increased amount of $1509.

Reviewer Comment (2017-01-12): Data correct on subsequent CDs (SFIG).

01/12/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201150240

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/113777)

Closing Disclosure is using the expired hazard insurance premiumof $1457. Updated policy in file has an increased amount of $1509.

Reviewer Comment (2017-01-12): Data correct on subsequent CDs (SFIG).

01/12/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201150240

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/17/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201150240

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,611.00 exceeds tolerance of $1,407.00 plus 10% or $1,547.70.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2017-01-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/17/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201150240

Credit

Credit

Credit Documentation

Aged document: Primary Valuation is older than guidelines permit

Appraisal and CDA are more than 120 day from Note Date.

Reviewer Comment (2017-01-11): 442 and updated CDA within timing requirements have been received.  Value is supported.

01/11/2017

1

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

D

B

201150241

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150241

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2017-01-06): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201150241

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150242

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201150242

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.14210% or Final Disclosure APR of 6.14500% is in excess of allowable threshold of APOR 3.19% + 2.5%, or 5.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150242

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.14210% or Final Disclosure APR of 6.14500% is in excess of allowable threshold of APOR 3.19% + 2.5%, or 5.69000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201150242

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-02-08): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-01-18): Received ARM disclosure dated 9/19.  Missing ARM disclosure that should have been supplied at initial application, 9/9. Reviewer Comment (2017-01-12): Lender sent in proof of LE receipt.  However, exception is for ARM Disclosure.

02/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150242

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2017-02-01): Received Insurer's Replacement Cost calculator.  Coverage is sufficient. Reviewer Comment (2017-01-18): The 10% Extended Replacement Coverage was already included in coverage calculations.  Missing insurer's replacement cost to show amount of coverage is sufficient.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150242

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201150242

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $15,300.00 exceeds tolerance of $169.00 plus 10% or $185.90.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2016-12-28): Fee was originally listed under recording fee.  Post close CD reflects fee in correct line, as transfer taxes.  Seller paid fee so no violation.

12/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201150243

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.48780% or Final Disclosure APR of 7.48800% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150243

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.48780% or Final Disclosure APR of 7.48800% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201150243

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150243

Credit

Credit

Misc

Credit Exception:

1. Cannot meet residual income requirement. 2. Using rental income on a departing residence that does not have 25% equity.

Reserves of 14 months is in excess of the 6 month required. LTV of 55% is significantly below the program max of 85%. Fresh start does not require a pay history, but the 25 most recent months have been documented as paid as agreed. Income of $1,266 exists that is not being used for qualification. Part of this is the difference in actual lease of $3,500 per month and appraiser value of $2,650 per month. The borrower also receives a bonus which is not being used for qualification.

Reviewer Comment (2016-12-28): Client elects to waive.

12/28/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201150244

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

715 representative FICO score > 660 guideline minimum - 55 points above guideline minimum

Reviewer Comment (2017-01-12): Client elects to waive.

01/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201150244

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.34420% or Final Disclosure APR of 6.36800% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150244

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Property taxes paid by Seller prior to closing were listed on Final CD, but not on Seller's CD

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150245

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150245

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

collateral desktop not in file but fee collected on CD.

Reviewer Comment (2017-01-09): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/09/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150246

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.65650% or Final Disclosure APR of 6.66200% is in excess of allowable threshold of APOR 3.52% + 1.5%, or 5.02000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150246

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150246

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-18): Data correct on subsequent CDs (SFIG).

01/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201150247

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

28 months reserves > 9 months guideline minimum

Reviewer Comment (2016-12-29): Client elects to waive.

12/29/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201150247

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Total Closing Costs Exceeds Limits Amount

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a tolerance cure amount that does not match the amount disclosed in the Other Costs table. (Interim/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150247

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-09): Fee is subject to 10% testing, not 0% as vendor is not an affiliate.  No violation.

01/09/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201150247

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150247

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee.  Fee Amount of $800.00 exceeds tolerance of $785.00.  Insufficent or no cure was provided to the borrower. (7561)

Fee paid to affiliate without VCC.

Reviewer Comment (2017-01-09): Fee is subject to 10% testing, not 0% as vendor is not an affiliate.  No violation. Reviewer Comment (2017-01-05): Received updated CD but tolerance violation not addressed.  Since vendor is an affiliate, subject to 0% testing.

01/09/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201150247

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2016-12-29): Cured at closing.

12/29/2016

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201150247

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower. (7580)

Reviewer Comment (2017-01-09): Cured at closing.

01/09/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150248

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.82610% or Final Disclosure APR of 6.83100% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201150248

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Documents were signed on [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201150248

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

37% DTI on this full documentation loan < 50% guideline max - 13% below program guideline maximum

Reviewer Comment (2016-12-29): Client elects to waive.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201150249

Compliance

Compliance

Federal Compliance

Retirement Documentation

Qualified Mortgage (Dodd-Frank 2014): Retirement income documentation insufficient.

Proof of continuance required for Appendix Q.

Reviewer Comment (2017-01-05): Used awards letter to deceased husband.

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150249

Compliance

Compliance

Federal Compliance

Social Security Documentation

Qualified Mortgage (Dodd-Frank 2014): Social Security income documentation insufficient.

Awards Letter required for Appendix Q.

Reviewer Comment (2017-01-09): SSI removed from qualification. Reviewer Comment (2017-01-05): Lender states that 1099 is in file.  However, Appendix Q is very specific in the documentation requirement:  Social Security income must be verified by a Social Security Administration benefit verification letter.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150249

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.27620% or Final Disclosure APR of 6.27600% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150249

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-01-09): Designation switched to Non-QM.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201150249

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.27620% or Final Disclosure APR of 6.27600% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201150249

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150249

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

18 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201150250

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Document Preparation Fee.  Fee Amount of $95.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7563)

Fee listed in Section B even though vendor is not listed on SSPL.

Reviewer Comment (2016-12-29): Cured at closing.

12/29/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

B

B

201150250

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $625.00 exceeds tolerance of $475.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2016-12-29): Cured at closing.

12/29/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

B

B

201150315

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

91 months reserves > 12 months guideline minimum Borrower on this loan has a disposable income of $16133

Reviewer Comment (2016-12-29): Client elects to waive.

12/29/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

No

C

B

201150315

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

No

C

B

201150315

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-03): Received evidence that borrower received disclosure within timing requirements.

01/03/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

C

B

201150315

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

C

B

201150315

Credit

Credit

Misc

Credit Exception:

Lender used rental income on subject property.

91 months reserves > 12 months guideline minimum Borrower on this loan has a disposable income of $16133

Reviewer Comment (2016-12-29): Client elects to waive.

12/29/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

No

C

B

201150315

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

91 months reserves > 12 months guideline minimum Borrower on this loan has a disposable income of $16133

Reviewer Comment (2016-12-29): Client elects to waive.

12/29/2016

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

No

C

B

201150316

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.90270% or Final Disclosure APR of 6.90300% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150316

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on [MM/DD/YYYY], prior to three (3) business days from transaction date of [MM/DD/YYYY].

Right To Cancel reflects an expiration date of [MM/DD/YYYY]; Final CD reflects a disbursement date of [MM/DD/YYYY]. Transaction is a Cash Out Refinance on a Primary Residence.

Reviewer Comment (2017-01-27): LOE, provide corrected CD with accurate information including disbursement date, new rescission form and rescission period and proof of delivery. Reviewer Comment (2017-01-09): Lender states that rescission was waived because lender refinanced a loan originated by the same lender.  This is only allowed if the principal balance has no new advances.  Principal balance rose due to debt consolidation.  The additional payoffs included in the new refinance would factor into what would be considered a new advance of money and therefore become subject to rescission. Only when no new money is being advanced by the same creditor would the exemption apply. Exception is valid.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201150316

Credit

Credit

Misc

Credit Exception:

CDA outside of 120 days from Note.  Appraisal has a 442 from original appraiser stating that value hasn't declined; but there is no such documentation from CDA confirming their value.

Reviewer Comment (2017-01-17): Received copy of updated CDA reflecting no variance.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150316

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $175.00 exceeds tolerance of $150.00.  Sufficient or excess cure was provided to the borrower. (75106)

Reviewer Comment (2016-12-30): Cured at closing.

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150317

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

35% DTI on this documentation loan < 50% guideline max - 15% below program guideline maximum

Reviewer Comment (2016-12-29): Client elects to waive.

12/29/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201150317

Credit

Assets

Asset Documentation

Asset Issue:  Gift funds are missing evidence of receipt

Evidence of donor ability and receipt of funds were not provided for gift of $.

Reviewer Comment (2017-01-18): Received attestation that the second gift was amended from the first.  No $30k gift was ever given or received. Reviewer Comment (2017-01-09): There are 2 gift letters in the file, one for $28,500 and one for $30,000.  Evidence of receipt of the $28,500 was evident in the original file and used in calculations.  No such evidence was found regarding $30,000 gift.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150317

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.05900% or Final Disclosure APR of 6.05900% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150317

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.05900% or Final Disclosure APR of 6.05900% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201150317

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150317

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150318

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

673 > required 660

Reviewer Comment (2016-12-30): Client elects to waive.

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201150318

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.83950% or Final Disclosure APR of 6.84000% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150318

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees on the buyers Closing Disclosure is $56,933.12; seller paid fees on the sellers Closing Disclosure is $52,433.12.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150318

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Courier / Express Mail / Messenger Fee.  Fee Amount of $109.80 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75187)

Courier fee disclosed as $0 on the LE dated [MM/DD/YYYY]; but disclosed as $109.80 on the Final Closing Disclosure.  Fee is listed in Section B but vendor is not on SSPL.

Reviewer Comment (2016-12-30): Cured at closing.

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150318

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $54.90 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75206)

Wire fee disclosed as $0 on the LE dated [MM/DD/YYYY]; but disclosed as $54.90 on the Final Closing Disclosure.  Fee is listed in Section B but vendor is not on SSPL.

Reviewer Comment (2016-12-30): Cured at closing.

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150319

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

702 representative FICO score > 660 guideline minimum - 42 points above guideline minimum

Reviewer Comment (2016-12-30): Client elects to waive.

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201150319

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.89750% or Final Disclosure APR of 6.90000% is in excess of allowable threshold of APOR 3.61% + 2.5%, or 6.11000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201150319

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

Prepaid interest reflects from $102.74 from [MM/DD/YYYY] to [MM/DD/YYYY] (16 days) in the amount of $1,530.56; calculated is $1,643.84.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150319

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for 10% tolerance violation $562 was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150319

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees on the buyers Closing Disclosure is $13,376.35; seller paid fees on the sellers Closing Disclosure is $12,429.35.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150319

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $3,168.30 exceeds tolerance of $2,246.00 plus 10% or $2,470.60.  Insufficient or no cure was provided to the borrower. (0)

$660.55 Seller Paid Transfer Tax (per seller CD) is listed as a Recording Fee on initial and final CDs and is being included in 10% tolerance testing.  A cure for $37.43 provided for (the actual) 10% violation is evident, however due to mislabeling of the fee on the CD, amount is not correct.

Reviewer Comment (2017-01-12): Fee correctly shown as transfer tax on post close CD.  No violation for recording fee and cure provided at closing sufficient.

01/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201150319

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects closing date as [MM/DD/YYYY]; mortgage notary date is [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150319

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.89750% or Final Disclosure APR of 6.90000% is in excess of allowable threshold of APOR 3.61% + 2.5%, or 6.11000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201150320

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-03): Received evidence that borrower received disclosure within timing requirements.

01/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150320

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150320

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-01-03): Received evidence that borrower received disclosure within timing requirements.

01/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150320

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Closing Disclosure included Seller's loan payoff

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201150320

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee was disclosed for $150 on final loan estimate

Reviewer Comment (2017-01-06): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/06/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201150320

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower:

Unable to locate 2014 and 2015 W2s and copy of business license mentioned in VVOE.

Reviewer Comment (2017-01-04): Received required documentation.

01/04/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201150322

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

The dti is 31% which is below the max of 43%. The residual income of $2,100 is in excess of the program requirements of $1,000.

Reviewer Comment (2017-01-05): Client elects to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201150322

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.91310% or Final Disclosure APR of 7.91300% is in excess of allowable threshold of APOR 4.12% + 1.5%, or 5.62000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201150322

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201150322

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201150322

Credit

Credit

Misc

Credit Exception:

Loan amount is less than $100,000 minimum.

The dti is 31% which is below the max of 43%. The residual income of $2,100 is in excess of the program requirements of $1,000.

Reviewer Comment (2017-01-03): Client elects to waive.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201150322

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $28.25 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7520)

Reviewer Comment (2017-01-03): Cured at closing.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201150323

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-01-09): Cleared incorrect exception.  Received title, not List of Counseling Orgs. Reviewer Comment (2017-01-05): Received copy of title.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201150323

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.90480% or Final Disclosure APR of 6.90500% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201150323

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects closing date as [MM/DD/YYYY]; mortgage notary date is [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201150323

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201150323

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $675.00.  Insufficent or no cure was provided to the borrower. (7506)

Appraisal fee disclosed as $675 on the LE dated [MM/DD/YYYY]; but disclosed as $700 on the Final Closing Disclosure. Cure was provided on Final CD.

Reviewer Comment (2016-12-30): Cured at closing

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201150323

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $27.03 exceeds tolerance of $25.00.  Insufficent or no cure was provided to the borrower. (7520)

Credit report fee disclosed as $25 on the LE dated [MM/DD/YYYY]; but disclosed as $27.03 on the Final Closing Disclosure. Cure was provided on Final CD.

Reviewer Comment (2016-12-30): Cured at closing.

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201150323

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.90480% or Final Disclosure APR of 6.90500% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201150323

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception provided in file.

Borrower on this Full documentation loan has a disposable income of $37,000. 17.2% DTI on this Full documentation loan < 50% guideline max - 32.8% below program guideline maximum

Reviewer Comment (2016-12-30): Client elects to waive.

12/30/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201150323

Credit

Credit

Misc

Credit Exception:

Missing copy of title.

Reviewer Comment (2017-01-09): Received copy of title.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201157666

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

42.10% DTI on this Full documentation loan <50% guideline max - 7.89% below program guideline maximum 21.43 months reserves > 3 months guideline minimum - borrowers have verified reserves of $103,698.14 Borrower on this Full documentation loan has a disposable income of $8,924.72

Reviewer Comment (2017-01-03): Client elects to waive.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157666

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.93220% or Final Disclosure APR of 7.93200% is in excess of allowable threshold of APOR 3.58% + 2.5%, or 6.08000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201157666

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on [MM/DD/YYYY] reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section. (Final/[MM/DD/YYYY])

Collateral Desktop Analysis reflects being paid to the lender.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157666

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees on the buyers closing Disclosure is $886.47; seller paid fees on the sellers Closing Disclosure is $16,219.58. Seller paid fees not listed on the borrowers Final CD, Borrower Realtor Commission of $15,359.70.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157666

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender approved exception provided in file.

42.10% DTI on this Full documentation loan <50% guideline max - 7.89% below program guideline maximum 21.43 months reserves > 3 months guideline minimum - borrowers have verified reserves of $103,698.14 Borrower on this Full documentation loan has a disposable income of $8,924.72

Reviewer Comment (2017-01-03): Client elects to waive.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157666

Credit

Credit

Misc

Credit Exception:

Verify amount used for taxes is accurate .  Amount appears to be pre-construction value and doesn't contain assessment that includes the structure.  Document provided reflects a taxable value of .  DTI subject to change.

Reviewer Comment (2017-01-10): Received amount that lender used for qualification, however amount is not consistent with amount on final CD.

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157666

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/115328)

Monthly Tax amount collected for escrow on final CD is not sufficient.

Reviewer Comment (2017-02-21): Data correct on subsequent CDs (SFIG).

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157666

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/115328)

Monthly Tax amount collected for escrow on final CD is not sufficient.

Reviewer Comment (2017-02-21): Data correct on subsequent CDs (SFIG).

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157666

Credit

Credit

Misc

Credit Exception:

CDA fee collected on final CD, but no report provided.

Reviewer Comment (2017-02-21): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201157667

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

707 representative FICO score > 660 guideline minimum -47 points above guideline minimum

Reviewer Comment (2017-01-05): Client elects to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201157667

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.60720% or Final Disclosure APR of 6.65600% is in excess of allowable threshold of APOR 3.49% + 1.5%, or 4.99000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.625%. Also HPML per lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201157667

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

Reviewer Comment (2017-01-03): This is cured on the [MM/DD/YYYY] post closing CD.

01/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201157667

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $20,712.71, final CD shows $21,311.93.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157667

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $870.00 exceeds tolerance of $610.00 plus 10% or $671.00.  Sufficient or excess cure was provided to the borrower. (0)

Reviewer Comment (2017-01-03): This was cured at settlement.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157667

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $695.00 exceeds tolerance of $435.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2017-01-04): Cured at closing.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157668

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

40 months reserves > 9 months guideline minimum

Reviewer Comment (2017-01-03): Client elects to waive.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157668

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.96530% or Final Disclosure APR of 7.96500% is in excess of allowable threshold of APOR 3.18% + 1.5%, or 4.68000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.875%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201157668

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 7.96530% or Final Disclosure APR of 7.96500% is in excess of allowable threshold of APOR 3.18% + 1.5%, or 4.68000%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201157668

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-02-01): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-01-27): Received evidence of receipt of CHARM booklet.  Exception is for ARM disclosure.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157668

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA (2010): Initial escrow account statement does not match charges on Final Closing Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201157668

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201157668

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Discount Point Percentage

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed Discount Point percentage that does not match disclosed calculated percentage of loan amount. (Final/[MM/DD/YYYY])

Discount Points Percentage shows as 3.518%, calculated percentage is 3.530%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157668

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

This field is blank. This field should have a numeric entry.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157668

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-03): This is corrected on the [MM/DD/YYYY] post closing CD.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157668

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75106)

Reviewer Comment (2017-01-03): This was cured at settlement.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157669

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.14340% or Final Disclosure APR of 9.14300% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201157669

Compliance

Compliance

State Compliance

Ohio Consumer Sales Practices Act Acknowledgement of Receipt of Home Mortgage Loan Information Document Not Signed)

Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Loan Information Document not signed by borrower(s).

Signed disclosure was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201157669

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201157669

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

Title - Survey Fee was added to disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157669

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender Exception in file on  allowing 85% LTV with 653 Fico

Borrower on this full documentation loan has a disposable income of $2907 12 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-03): Client elects to waive.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157670

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-09): Received evidence that borrower received disclosure within timing requirements.

01/09/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

N/A

No

C

B

201157670

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Seller Credit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Seller Credit that does not match the Seller Credit from the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Cash to Close table has Seller Credit of $0. Summaries of Transactions table has a $5,000 Seller Creit

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201157670

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201157670

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-01-09): Received evidence that borrower received disclosure within timing requirements.

01/09/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

N/A

No

C

B

201157670

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201157670

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2017-01-11): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/11/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

N/A

Yes

C

B

201157670

Compliance

Compliance

Federal Compliance

Investment Property Submitted as QM

Qualified Mortgage (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Qualified Mortgage requirements.

Used designation that was pre-loaded

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

No

C

B

201157671

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-05): Received evidence that borrower received disclosure within timing requirements.

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201157671

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157671

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-01-19): Received evidence that borrower received disclosure within timing requirements.

01/19/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201157671

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-01-09): Received evidence that borrower received disclosure within timing requirements.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201157671

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.48840% or Final Disclosure APR of 6.48800% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201157672

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

26% DTI on this full documentation loan < 50% guideline max - 25% below program guideline maximum

Reviewer Comment (2017-01-03): Client elects to waive.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157672

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.97040% or Final Disclosure APR of 7.97000% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201157672

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

LE disclosure issued [MM/DD/YYYY] was issued on the "Without Seller" form, and LE issued [MM/DD/YYYY] and Final CD was issued on the "With Seller" form.

Reviewer Comment (2017-01-03): This is allowed on brokered loans.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157672

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-06): Received evidence that borrower received disclosure within timing requirements.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157672

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $53.50 exceeds tolerance of $50.00.  Insufficent or no cure was provided to the borrower. (7520)

Cured by lender

Reviewer Comment (2017-01-03): Cured at closing.

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly insurance indicated to be $67.42 mo.  Annual premium of $735.00 / 12 = $61.25.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for Title - Insurance Binder of $125.00 was not provided.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $12,762.20, final CD shows $13,035.000.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Insurance Binder Fee.  Fee Amount of $125.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7566)

Fee was not disclosed on Loan Estimate.  Fee is listed in Section B but vendor is not on SSPL.

Reviewer Comment (2017-02-02): Fee moved to correct section and no longer part of tolerance testing. Reviewer Comment (2017-02-01): Fee still listed in Section B on updated CD.

02/02/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/114718)

This violation is triggering due to the incorrect monthly insurance payment indicated in section G.

Reviewer Comment (2017-02-01): Data correct on subsequent CDs (SFIG).

02/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/114719)

This violation is triggering due to the incorrect monthly insurance payment indicated in section G.

Reviewer Comment (2017-02-01): Data correct on subsequent CDs (SFIG).

02/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/114720)

This violation is triggering due to the incorrect monthly insurance payment indicated in section G.

Reviewer Comment (2017-02-01): Data correct on subsequent CDs (SFIG).

02/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/114721)

This violation is triggering due to the incorrect monthly insurance payment indicated in section G.

Reviewer Comment (2017-02-01): Data correct on subsequent CDs (SFIG).

02/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157673

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/114718)

This violation is triggering due to the incorrect monthly insurance payment indicated in section G.

Reviewer Comment (2017-02-01): Data correct on subsequent CDs (SFIG).

02/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201157674

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

16 months > 9 months required.

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157674

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.79840% or Final Disclosure APR of 7.79800% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201157674

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $18,928, final CD shows $17,805.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157674

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $40.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (75197)

Reviewer Comment (2017-01-03): This was cured at settlement

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157674

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Notary Fee.  Fee Amount of $125.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7568)

Reviewer Comment (2017-01-03): This was cured at settlement

01/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157675

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

25.67% DTI on this Full documentation loan < 50% guideline max - 24% below program guideline maximum Borrower has job stability for 30 years as a [REDACTED] 688 representative FICO score > 620 guideline minimum - 68 points above guideline minimum Borrower on this Full documentation loan has a disposable income of $7,819.39.

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157675

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

Including EMD, total assets for closing short liquid assets short $1322.32

Reviewer Comment (2017-01-13): Received updated statements that show enough liquid assets for closing.

01/13/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157675

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-06): Received evidence that borrower received disclosure within timing requirements.

01/06/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157675

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-01-06): Received evidence that borrower received disclosure within timing requirements.

01/06/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157675

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $212.30 exceeds tolerance of $190.00 plus 10% or $209.00.  Insufficient or no cure was provided to the borrower. (0)

Did not exceed tolerance - Seller paid fee to cure title per purchase contract.

Reviewer Comment (2017-01-04): Cured at closing.

01/04/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201157675

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $89.50 exceeds tolerance of $40.00.  Insufficent or no cure was provided to the borrower. (7520)

No Change of Circumstance in file for this change

Reviewer Comment (2017-01-04): Cured at closing.

01/04/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201157675

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2017-01-13): Received updated asset statements reflecting sufficient liquid assets.

01/13/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157676

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

CDA fee charged on CD but no report supplied.

Borrower on this full documentation loan has a disposable income of $12166 61 months reserves > 9 months guideline minimum

Reviewer Comment (2017-01-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157676

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201157676

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing vs Closing Disclosure

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-01-17): Received attestation that disclosure was produced by title and never presented to borrower.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157676

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee not listed on Change of Circumstance in file

Reviewer Comment (2017-01-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201157676

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-01-20): Received evidence that borrower received disclosure within timing requirements.

01/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201157676

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

LENDER APPROVED exception for DTI

Borrower on this full documentation loan has a disposable income of $12166 61 months reserves > 9 months guideline minimum

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201157676

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-04): All guidelines violations have been addressed by lender.

01/04/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201157676

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-04): All guidelines violations have been addressed by lender.

01/04/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201170173

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

75% LTV < 85% guideline max

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201170173

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.77540% or Final Disclosure APR of 6.77500% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

Note rate 6.625%

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201170173

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $9,080.00, final CD shows $12,912.17.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201170173

Credit

Credit

Misc

Credit Exception:

Residual income short by $166.

75% LTV < 85% guideline max

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201170174

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender Approved the exception.

Guideline variance approved by lender at time of origination Max DTI for the program was 43.00% borrower DTI was 44.804% Borrower possesses over 18 months of reserves, (requirement is 9) Guideline variance approved by lender at time of origination Minimum credit score of 680 required, borrower low mid score is 678. credit file contains no delinquencies credit history is solid but limited. Borrower has strong reserve assets and property is new construction an increasing value area

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201170174

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Guideline variance approved by lender at time of origination Max DTI for the program was 43.00% borrower DTI was 44.804% Borrower possesses over 18 months of reserves, (requirement is 9) Guideline variance approved by lender at time of origination Minimum credit score of 680 required, borrower low mid score is 678. credit file contains no delinquencies credit history is solid but limited. Borrower has strong reserve assets and property is new construction an increasing value area

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201170174

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201170174

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201170174

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-08): Data correct on subsequent CDs (SFIG).

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201170174

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $485.00.  Sufficient or excess cure was provided to the borrower. (7506)

Lender provided a cure of $221.34 to solve.

Reviewer Comment (2017-01-04): Cured at closing.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201170174

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $81.34 exceeds tolerance of $75.00.  Sufficient or excess cure was provided to the borrower. (7520)

Lender provided a cure of $221.34 to solve.

Reviewer Comment (2017-01-04): Cured at closing.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201170174

Compliance

Compliance

Federal Compliance

ARM Disclosure Status

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.

Reviewer Comment (2017-01-27): Received evidence that borrower received disclosure within timing requirements.

01/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201170174

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.01130% or Final Disclosure APR of 6.01500% is in excess of allowable threshold of APOR 3.27% + 2.5%, or 5.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201170174

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Guideline variance approved by lender at time of origination Max DTI for the program was 43.00% borrower DTI was 44.804% Borrower possesses over 18 months of reserves, (requirement is 9) Guideline variance approved by lender at time of origination Minimum credit score of 680 required, borrower low mid score is 678. credit file contains no delinquencies credit history is solid but limited. Borrower has strong reserve assets and property is new construction an increasing value area

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201170174

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-04): All guidelines violations have been addressed by lender.

01/04/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201170174

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-04): All guidelines violations have been addressed by lender.

01/04/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201170175

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

CDA fee charged on CD but no report provided.

787 representative FICO score > 660 guideline minimum - 127 points above guideline minimum

Reviewer Comment (2017-01-19): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive. Reviewer Comment (2017-01-17): Received corrected CD with fee removed, but no copy of refund check.

01/19/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201170175

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-06): Received evidence that borrower received disclosure within timing requirements.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201170175

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-17): Fees moved to correct Section, C, and no longer part of tolerance testing.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201170175

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201170175

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Processing Fee.  Fee Amount of $375.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75195)

Fee in Section B, vendor not on SSPL.  No CoC referencing fee provided.

Reviewer Comment (2017-01-17): Fees moved to correct Section, C, and no longer part of tolerance testing.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201170175

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - SubEscrow Fee.  Fee Amount of $62.50 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75201)

Fee in Section B, vendor not on SSPL.  No CoC referencing fee provided.

Reviewer Comment (2017-01-17): Fees moved to correct Section, C, and no longer part of tolerance testing.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201170175

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Notary Fee.  Fee Amount of $280.00 exceeds tolerance of $200.00.  Insufficent or no cure was provided to the borrower. (7568)

Reviewer Comment (2017-01-17): Fees moved to correct Section, C, and no longer part of tolerance testing.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201178330

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reserves substantially in excess of guideline requirements:  Borrower has total of 24 months reserves when 6 months is required.  ($100,600 is verified assets when $24,350 is required). LTV is significantly below program guidelines: LTV @ 75% when max LTV is 90%. On time housing payment history at current location.  Borrower has 34 months on time mortgage payment history.

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178330

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved Exception.

Reserves substantially in excess of guideline requirements:  Borrower has total of 24 months reserves when 6 months is required.  ($100,600 is verified assets when $24,350 is required). LTV is significantly below program guidelines: LTV @ 75% when max LTV is 90%. On time housing payment history at current location.  Borrower has 34 months on time mortgage payment history.

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178330

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.26750% or Final Disclosure APR of 6.26800% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201178330

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-04): All guidelines violations have been addressed by lender.

01/04/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201178330

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-04): All guidelines violations have been addressed by lender.

01/04/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178330

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.26750% or Final Disclosure APR of 6.26800% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201178330

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178331

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

78 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-04): Client elects to waive.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178331

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.32580% or Final Disclosure APR of 6.32600% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201178331

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $25,494, final CD shows $287,352.51.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178331

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,750.00 exceeds tolerance of $1,500.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee disclosed as $1,500.00 on all LE''s, but disclosed as $1,750.00 on Final Closing Disclosure.

Reviewer Comment (2017-01-04): This is cured on the final CD.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201178332

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this Full documentation loan has a disposable income of $11,187.80 80% LTV, 90% maximum. 44.63 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-05): Client elect to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178332

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.93520% or Final Disclosure APR of 5.93500% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201178332

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.93520% or Final Disclosure APR of 5.93500% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201178332

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $714,901.45, final CD shows $635,680.72

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178332

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2017-01-04): This was cured at settlement

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178332

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7507)

Reviewer Comment (2017-01-04): This was cured at settlement.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178332

Credit

Credit

Misc

Credit Exception:

Lender Approved an Overlay Exception for 5 comparable sales, 4 closed and 1 listing.  Guidelines require a minimum of 6 comparable sales, 4 closed and two listing.  Investor Guidelines do not require a minimum number of Comps.

Borrower on this Full documentation loan has a disposable income of $11,187.80 80% LTV, 90% maximum. 44.63 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-05): Client elect to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178332

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $83.66 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower. (7520)

Reviewer Comment (2017-01-04): Final CD reflects $433.36 Lender Credit for tolerance cure.

01/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178333

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.07960% or Final Disclosure APR of 8.08000% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201178333

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

First and second mortgage payoffs were listed under Section H on Final CD, therefore including to total closing costs paid by seller causing discrepancy with Seller CD which does not include mortgage payoffs in closing costs paid.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201178695

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.81820% or Final Disclosure APR of 7.82200% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201178695

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

Final Closing Disclosure removed 4 fees in section C and combined them into Title-Endorsement Fees

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201178695

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201178696

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception for DTI to 56.61%.

Guideline variance approved by lender at time of origination.  On [MM/DD/YYYY], Caliber approved DTI of 53.4% based on:  69 months of reserves; satisfactory history of paying alimony for 18 months;  DTI will be reduced to 43% when alimony obligation ceases in 18 months; Borrower has residual income in excess of guideline; borrower has 45 month perfect mortgage pay history, in excess of the required 24 months; 75% LTV lower than 90% for which borrower qualifies.  Refer to lender approval on page 248 Borrower on this (Documentation Type) documentation loan has a disposable income of $8,420;  Program requires $4,700 Borrower has employment stability for 20 years as [REDACTED].

Reviewer Comment (2017-01-05): Client elects to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178696

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-05): All guidelines violations have been addressed by lender.

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201178696

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Exception approved by lender

Reviewer Comment (2017-01-05): All guidelines violations have been addressed by lender.

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178696

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for Recording Fee of $43.80 was not provided.

Reviewer Comment (2017-01-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178696

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $200.00 exceeds tolerance of $142.00 plus 10% or $156.20.  Insufficient or no cure was provided to the borrower. (0)

$43.80 violation due to increase in Recording fee.  No evidence of cure.

Reviewer Comment (2017-01-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201178696

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

On final CD, all fees disclosed in Section B, but borrower did not use vendor on SSPL.  Title fees should have been disclosed in Section C.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178696

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Guideline variance approved by lender at time of origination.  On [MM/DD/YYYY], Caliber approved DTI of 53.4% based on:  69 months of reserves; satisfactory history of paying alimony for 18 months;  DTI will be reduced to 43% when alimony obligation ceases in 18 months; Borrower has residual income in excess of guideline; borrower has 45 month perfect mortgage pay history, in excess of the required 24 months; 75% LTV lower than 90% for which borrower qualifies.  Refer to lender approval on page 248 Borrower on this (Documentation Type) documentation loan has a disposable income of $8,420;  Program requires $4,700 Borrower has employment stability for 20 years as [REDACTED].

Reviewer Comment (2017-01-05): Client elects to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178697

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual Income - Required: $1,930 vs Actual : $2,534.21 HOA R/T with 710 FICO allows 90% w/ 5% reduction due to Condo Risk Level 3%: 85%. Current LTV: 79.49% Significant reduction in housing payment as supported by NTB. 21% reduced payment.

Reviewer Comment (2017-01-05): Client elects to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178697

Credit

Assets

Asset Documentation

Aged document: Asset Account is older than guidelines permit

Financial Institution:  / End Date: [MM/DD/YYYY] // Account Type: Checking / Account Number:

Guidelines limit ageing to 90 days.

Reviewer Comment (2017-01-17): Received updated asset statement.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178697

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.90800% or Final Disclosure APR of 6.90800% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.625%

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201178697

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Non-Warrantable condo's are limited to 43% DTI. Lender exception approval provided.

Residual Income - Required: $1,930 vs Actual : $2,534.21 HOA R/T with 710 FICO allows 90% w/ 5% reduction due to Condo Risk Level 3%: 85%. Current LTV: 79.49% Significant reduction in housing payment as supported by NTB. 21% reduced payment.

Reviewer Comment (2017-01-05): Client elects to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178697

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

Evidence of earlier borrower receipt was not found in file.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201178697

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-05): All guidelines violations have been addressed by lender.

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201178697

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-05): All guidelines violations have been addressed by lender.

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178697

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

Title - Lien Search changed to Title - Title Examination.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178698

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Reviewer Comment (2017-01-12): VOM not required for Fresh Start program.

01/12/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178698

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

22 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-05): Client elects to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178698

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201178698

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-09): Received evidence that borrower received disclosure within timing requirements.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178698

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201178698

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.02860% or Final Disclosure APR of 8.03000% is in excess of allowable threshold of APOR 3.21% + 1.5%, or 4.71000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201178699

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.54690% or Final Disclosure APR of 6.58700% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-01-09): Received copy of lease.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178699

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-01-09): Received copy of lease.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178699

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail.

Reviewer Comment (2017-01-09): Received copy of lease.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201178699

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - REO 25% Method

Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income (25% Method) using reasonably reliable third-party records. (Non-Subject Investment/25% Vacancy Method)

Missing lease agreement

Reviewer Comment (2017-01-09): Received copy of lease.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178699

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Reviewer Comment (2017-01-09): Received copy of lease.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201178699

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Corrected on post-close disclosure

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178699

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.54690% or Final Disclosure APR of 6.58700% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201178700

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees on the buyers Closing Disclosure is $1,209,836.06; seller paid fees on the sellers Closing Disclosure is $147,957.88.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201178700

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $66.03 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7520)

Credit report fee disclosed as $0 on the LE dated 11/9/16; but disclosed as $66.03 on the Final Closing Disclosure.

Reviewer Comment (2017-01-06): Cured at closing.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201178700

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $8.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7579)

Flood Cert fee disclosed as $0 on the LE dated 11/9/16; but disclosed as $8 on the Final Closing Disclosure.

Reviewer Comment (2017-01-06): Cured at closing.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201178700

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7580)

Tax Service fee disclosed as $0 on the LE dated 11/9/16; but disclosed as $92 on the Final Closing Disclosure.

Reviewer Comment (2017-01-06): Cured at closing.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201178700

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Loan was qualified with monthly tax payment of $; closing disclosure reflects  $a month.

Borrower on this full documentation loan has a disposable income of $14650 11 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201178700

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-11): All guidelines violations have been addressed by lender.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201178700

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-11): All guidelines violations have been addressed by lender.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201178701

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.84820% or Final Disclosure APR of 6.87700% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201178701

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.84820% or Final Disclosure APR of 6.87700% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201178701

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender approved.

Borrower on this Full documentation loan has a disposable income of $15,298.79 41.36% DTI on this Full documentation loan < 50% guideline maximum Borrower has job stability for 15 years as a [REDACTED]

Reviewer Comment (2017-01-05): Client elects to waive.

01/05/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183015

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

B

B

201183016

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this full documentation loan has a disposable income of $10,549.56. A combination of rent and mortgage payments provided to show 0x30x36 which is above base requirement of 24 months

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201183016

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.22740% or Final Disclosure APR of 6.22700% is in excess of allowable threshold of APOR 3.50% + 2.5%, or 6.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201183016

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201183016

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Borrower on this full documentation loan has a disposable income of $10,549.56. A combination of rent and mortgage payments provided to show 0x30x36 which is above base requirement of 24 months

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201183016

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

A

A

A

A

A

Higher Priced QM

Non QM

Yes

C

B

201183016

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

QM qualification requires the use of the maximum rate in the first 5 years method.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201183016

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201183017

Credit

Loan Package Documentation

Closing / Title

Missing Document: Rider - ARM not provided

Arm Rider was not located in file.

Reviewer Comment (2017-01-10): Received copy of ARM Rider.

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183017

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Required.

Guideline variance approved by lender at time of origination.  Compensating Factor:  LTV of 56%.  24% below program maximum of 80%. Borrower on this full documentation loan has a disposable income of $$2656.46 in excess of $1200 required. Reserves > 3 months guideline minimum - borrowers have verified reserves of 18 months.

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183017

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.79900% or Final Disclosure APR of 6.79900% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201183017

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender requested exception to go to 50.864% when 50% is the max with a 657 FICO, however, DTI is 62.531%.

Guideline variance approved by lender at time of origination.  Compensating Factor:  LTV of 56%.  24% below program maximum of 80%. Borrower on this full documentation loan has a disposable income of $$2656.46 in excess of $1200 required. Reserves > 3 months guideline minimum - borrowers have verified reserves of 18 months.

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183017

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-06): All guidelines violations have been addressed by lender.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201183017

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-06): All guidelines violations have been addressed by lender.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183017

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.79900% or Final Disclosure APR of 6.79900% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-01-06): All guidelines violations have been addressed by lender.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183017

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-01-06): All guidelines violations have been addressed by lender.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183017

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.79900% or Final Disclosure APR of 6.79900% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Non QM

Non QM

No

C

B

201183018

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201183018

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

Reviewer Comment (2017-01-06): This was cured at settlement.

01/06/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201183018

Credit

Credit

Misc

Credit Exception:

Use of gift funds were used to purchase a second home. Lender exception approved.

Residual Income: $7,200.00; Verified $8,937.07; Excess of $1,737.07. 9 months required have reserves of 20 months. Bonus income not being used. Verified 33 months, 12 months required.

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183018

Credit

Credit

Misc

Credit Exception:

First time home buyer purchasing a second home. Lender exception approved.

Residual Income: $7,200.00; Verified $8,937.07; Excess of $1,737.07. 9 months required have reserves of 20 months. Bonus income not being used. Verified 33 months, 12 months required.

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183019

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

29% DTI on this full documentation loan < 43% guideline max - 14% below program guideline maximum LTV 77% > 85% guideline 40 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201183019

Credit

Loan Package Documentation

Application / Processing

Missing Document: Other not provided

LENDER APPROVED EXCEPTION: Borrower has stated she is separated but does not have legal separation or divorce decree. Accepting notarized affidavit between parties to document liabilities and assets to each individual.

29% DTI on this full documentation loan < 43% guideline max - 14% below program guideline maximum LTV 77% > 85% guideline 40 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201183019

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.10660% or Final Disclosure APR of 7.15800% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201183019

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $10,366.75 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $2,407.65.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201183020

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Required Residual Income $2,300.00. Actual $2,926.19, Exceeds by $626.19. Required 3 months. Actual 32 months.

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183020

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Non QM per Job Notes.

Reviewer Comment (2017-01-06): All guidelines violations have been addressed by lender.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201183020

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-06): All guidelines violations have been addressed by lender.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183020

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $855.00 exceeds tolerance of $595.00.  Sufficient or excess cure was provided to the borrower at Closing. (73196)

Zero Percent Fee Tolerance exceeded for Underwriting Fee. Fee Amount of $855.00 exceeds tolerance of $595.00. Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2017-01-05): Cured at settlement

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201183020

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7505)

ero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee. Fee Amount of $150.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing

Reviewer Comment (2017-01-05): Cured at settlement

01/05/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201183020

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-01-18): Received evidence that disclosure was provided within 3 days of program change. Reviewer Comment (2017-01-10): Lender sent in CD.  Exception is for ARM disclosure.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183020

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception for 50.373% page and 2nd PDF.

Required Residual Income $2,300.00. Actual $2,926.19, Exceeds by $626.19. Required 3 months. Actual 32 months.

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183020

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.84180% or Final Disclosure APR of 6.84200% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-01-06): All guidelines violations have been addressed by lender.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183020

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-01-06): All guidelines violations have been addressed by lender.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183020

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.84180% or Final Disclosure APR of 6.84200% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

Non QM

Non QM

No

C

B

201183021

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.97720% or Final Disclosure APR of 9.03000% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 8.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201183021

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $15,039.72, final CD shows $13,560.06.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201183021

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Only page 1 of report was provided. Missing balance of the report

Reviewer Comment (2017-01-26): Received attestation that red flags have been addressed and lender accepts report. Reviewer Comment (2017-01-13): Received copy of full report.  However, report is in high risk category.  Red Flags must be addressed.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201183023

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

$150,000.00 shortfall. No documentation supporting a lower cost to rebuild was provided.

Reviewer Comment (2017-01-11): Received copy of insurance estimator reflecting coverage is sufficient.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201183023

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.12230% or Final Disclosure APR of 6.12200% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.125%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201183023

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201183023

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

26% DTI on this full documentation loan < 50% guideline max - 24% below program guideline maximum

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201183024

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $72,124.71, final CD shows $1,056.00. Note: The post funding [MM/DD/YYYY] CD altered this to $73,055.71.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201183024

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.08010% or Final Disclosure APR of 7.08200% is in excess of allowable threshold of APOR 3.61% + 2.5%, or 6.11000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.875%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201183024

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $645.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-01-06): This was cured at settlement.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201183024

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

701 representative FICO score > 620 guideline minimum - 81 points above guideline minimum

Reviewer Comment (2017-01-06): Client elect to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183025

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

21% DTI on this full documentation loan < 50% guideline max - 29% below program guideline maximum

Reviewer Comment (2017-01-06): Client elects to waive.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201183025

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.54190% or Final Disclosure APR of 8.60100% is in excess of allowable threshold of APOR 3.98% + 2.5%, or 6.48000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201183025

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $36,970.85 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $1,018.50,

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201183025

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $90.00 exceeds tolerance of $65.00 plus 10% or $71.50.  Sufficient or excess cure was provided to the borrower at Closing. (0)

No violation - Cure provided on Closing Disclosure

Reviewer Comment (2017-01-06): Lender provided $143.00 credit at closing for increase in Closing Costs above legal limit.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201183025

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $634.00 exceeds tolerance of $534.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

No violation - Cure provided on Closing Disclosure

Reviewer Comment (2017-01-06): Lender provided $143.00 credit at closing for increase in Closing Costs above legal limit.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201183025

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $74.50 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

No violation - Cure provided on Closing Disclosure

Reviewer Comment (2017-01-06): Lender provided $143.00 credit at closing for increase in Closing Costs above legal limit.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201183026

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

10 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201183026

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-01-11): Received evidence that borrower received disclosure within timing requirements.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183026

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201183026

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $31.00 exceeds tolerance of $25.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-01-09): Cured at closing.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201183026

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.22270% or Final Disclosure APR of 7.23400% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201191216

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

37% DTI on this full documentation loan < 50% guideline max - 13% below program guideline maximum

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201191216

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.28870% or Final Disclosure APR of 6.28900% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201191216

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201191216

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $43,323.74 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $375,494.67.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201191217

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34% DTI on this full documentation loan < 50% guideline max - 16% below program guideline maximum

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201191217

Credit

Credit

Credit Eligibility

Public Record Issue:

Credit Report: Original // Public Record Type: Tax Liens / Balance:

Final closing disclosure reflects  was paid at closing.  Title shows initial liens were $and $. Page  is an approval from the IRS to subordinate the tax lien. Final Title Policy must reflect lien was subordinated.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201191217

Compliance

Compliance

Federal Compliance

QM Employment History

Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.

Job history is measured to application date.  Missing employment prior toto complete full 2 year history.

Reviewer Comment (2017-01-25): Received full 2 yr history. Reviewer Comment (2017-01-11): Received same VVOE that was in original submission.  Job history is measured from application date, and VVOE does not support a 2 year history.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201191217

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Two year employment history for borrower was not provided.

Reviewer Comment (2017-01-25): Received full 2 yr history.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201191217

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-11): Received evidence that borrower received disclosure within timing requirements.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201191217

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.17350% or Final Disclosure APR of 7.17400% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201191217

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $575.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-01-09): Final closing disclosure reflects a cure of $25.00.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201191218

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.95990% or Final Disclosure APR of 6.96000% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

Note rate 7.375%

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201191218

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.95990% or Final Disclosure APR of 6.96000% is in excess of allowable threshold of APOR 3.23% + 2.5%, or 5.73000%.  Compliant Higher Priced Loan.

Note rate 7.375%

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201191218

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

The[MM/DD/YYYY] initial LE is on a with seller form. All other LE's and CD's are on the without seller form.

Reviewer Comment (2017-01-10): Allowed for brokered loans.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191218

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $1,537.50 exceeds tolerance of $1,341.00.  Sufficient or excess cure was provided to the borrower at Closing. (7200)

Reviewer Comment (2017-01-10): This was cured at settlement.

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201191218

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-01-12): Received evidence that borrower received disclosure within timing requirements.

01/12/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201191218

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Maximum program LTV is 80%. Exception approval provided to 90% LTV.

The residual income is above the min required amount by 3500. 1st mortgage [REDACTED] 0 lates in past 33 months. 2nd lien [REDACTED] 0 lates past 99 months.

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191218

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Maximum loan amount is $1,000,000.00 per lender guidelines. Lender exception approval provided is for an LTV exception to9 0.00% LTV.  It does not approve a loan limit exception.

The residual income is above the min required amount by 3500. 1st mortgage [REDACTED] 0 lates in past 33 months. 2nd lien [REDACTED] 0 lates past 99 months.

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191218

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Fee was charged on final CD but no report provided.

The residual income is above the min required amount by 3500. 1st mortgage [REDACTED] 0 lates in past 33 months. 2nd lien [REDACTED] 0 lates past 99 months.

Reviewer Comment (2017-01-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191219

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

116 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191219

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.92950% or Final Disclosure APR of 7.93000% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201191219

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.92950% or Final Disclosure APR of 7.93000% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201191219

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

The Final Closing Disclosure reflects a closing date of [MM/DD/YYYY], the mortgage notary reflects a date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191219

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

The Final Closing Disclosure reflects Homeowners prepaid of $824.37 for 12 months-this equals $68.70 monthly. The Initial Escrow reflects Homeowners insurance of $178.30 monthly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191219

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191219

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $76.00 exceeds tolerance of $54.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

The Final Closing Disclosure reflects a cost to cure of $22.00.

Reviewer Comment (2017-01-09): Cured at closing.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201191220

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.41550% or Final Disclosure APR of 8.41600% is in excess of allowable threshold of APOR 3.55% + 1.5%, or 5.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201191220

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Missing Secondary Valuation

36.71% DTI on this full documentation loan < 50% guideline max Borrower on this full documentation loan has a residual income of $3569.34 > guideline requirement of $1950.00 Significant NTB: 23.7% reduced PITIA

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201191220

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

36.71% DTI on this full documentation loan < 50% guideline max Borrower on this full documentation loan has a residual income of $3569.34 > guideline requirement of $1950.00 Significant NTB: 23.7% reduced PITIA

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201191221

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

C

B

201191221

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date [MM/DD/YYYY] - corrected in Post Close CD

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

C

B

201191221

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

No evidence of receipt date in file

Reviewer Comment (2017-01-12): Received evidence that borrower received disclosure within timing requirements.

01/12/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Exempt from ATR

N/A

No

C

B

201191222

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee charged on CD but no report provided.

Residual income required is $2,300 and verified is $3,543.81. Have verified more than 48 months of current rental and mortgage history from credit report and VOR. Only 24 months is required.

Reviewer Comment (2017-01-20): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201191222

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-18): Data correct on subsequent CDs (SFIG).

01/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

D

B

201191222

Credit

Credit

Misc

Credit Exception:

To allow 90% LTV with a DTIi of 46.158%. Max allowed is 45%.

Residual income required is $2,300 and verified is $3,543.81. Have verified more than 48 months of current rental and mortgage history from credit report and VOR. Only 24 months is required.

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201191222

Compliance

Compliance

Federal Compliance

TRID - the file contains an illegible TRID disclosure. Testing is incomplete

contains an incomplete closing disclosure issued 12/1.

Reviewer Comment (2017-01-19): Received attestation that disclosure was produced by title and never presented to borrower.

01/19/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

A

D

A

D

A

D

A

D

A

Non QM

Non QM

Yes

D

B

201191222

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.68490% or Final Disclosure APR of 6.68500% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

D

B

201191223

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee was charged on CD but no report provided.

25months reserves > 9 months guideline minimum

Reviewer Comment (2017-01-30): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive. Buyer Comment (2017-01-11): Please disregard upload, [MM/DD/YYYY] done error.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201191223

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-12): Received evidence that borrower received disclosure within timing requirements.

01/12/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201191223

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-18): Data correct on subsequent CDs (SFIG).

01/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201191223

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.84090% or Final Disclosure APR of 6.84100% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201191223

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

A

A

A

A

A

Higher Priced QM

Non QM

Yes

C

B

201191223

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201191223

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201191224

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

26% DTI on this full documentation loan < 50% guideline max - 24% below program guideline maximum

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201191224

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.04130% or Final Disclosure APR of 8.04100% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201191224

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $38.06 exceeds tolerance of $30.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-01-10): Cure of $8.06 provided on final closing disclousre.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201191224

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-10): Cure of $8.06 was provided on final closing disclosure.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201191224

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Final closing disclosure reflects seller paid fees of $116,655.72. Seller closing disclosure reflects seller paid fees of $7,305.70.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201191224

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $38.06 exceeds tolerance of $30.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-01-10): Cure provided on final closing disclosure.

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201191225

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee was charged on CD but no report provided.

Borrower on this full documentation loan has residual income of $7,483.68 > required amount of $5,900.00 45.676% DTI on this full documentation loan < 50% guideline max Borrower's employment offer reflects incentive that the borrower will be receiving and was not used to qualify the loan.

Reviewer Comment (2017-01-20): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive. Buyer Comment (2017-01-11): Please disregard upload [MM/DD/YYYY] 12:01 pm done in error.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191225

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.00410% or Final Disclosure APR of 7.00400% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201191225

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191225

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

LENDER APPROVED EXCEPTION:  Appraisal reflects "declining" values, per guidelines a 5% LTV reduction is required.  Exception approved to proceed without LTV reduction.

Borrower on this full documentation loan has residual income of $7,483.68 > required amount of $5,900.00 45.676% DTI on this full documentation loan < 50% guideline max Borrower's employment offer reflects incentive that the borrower will be receiving and was not used to qualify the loan.

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191225

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $374.00 exceeds tolerance of $324.00 plus 10% or $356.40.  Sufficient or excess cure was provided to the borrower at Closing. (0)

No Change of Circumstance in file affecting ten percent tolerance

Reviewer Comment (2017-01-09): Cured at closing.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201191225

Credit

Credit

Misc

Credit Exception:

Lender is excluding student loan payment from DTI Calcs.  Unable to locate proof that payment start date is > 12 months from Note Date.   document in file with  balance shows payments to begin .

Reviewer Comment (2017-01-12): Payments added to DTI.

01/12/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201191226

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.57720% or Final Disclosure APR of 8.57700% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201191226

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

Reviewer Comment (2017-01-10): Cured at closing.

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

B

B

201191226

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-01-10): Cured at closing.

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

B

B

201191226

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201191227

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

721 representative FICO score > 680 guideline minimum - 41 points above guideline minimum

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201191227

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-12): Received evidence that borrower received disclosure within timing requirements.

01/12/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201191227

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201191228

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income required $6,600, actual $12,641.82; Difference $6,041.83. (5) Dependents. Required 9 months; borrower has 35 months with remaining net 401k. Maximum allowed 50.000%; borrower's DTI 38,796%.

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191228

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.27430% or Final Disclosure APR of 7.56900% is in excess of allowable threshold of APOR 3.61% + 2.5%, or 6.11000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.25%

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201191228

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/117916)

Reviewer Comment (2017-01-06): This is corrected on the [MM/DD/YYYY] post closing CD.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201191228

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Interest Rate that does not match the actual interest rate for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-06): This is corrected on the [MM/DD/YYYY] post closing CD.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201191228

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Principal and Interest

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Principal and Interest Payment that does not match the actual payment for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-06): This is corrected on the [MM/DD/YYYY] post closing CD.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201191228

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Payment Min Payment Fixed Rate Initial Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/117916)

Reviewer Comment (2017-01-06): This is corrected on the [MM/DD/YYYY] post closing CD.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201191228

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-06): This is corrected on the [MM/DD/YYYY] post closing CD.

01/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191228

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201191228

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Credit score of 658 is less than 680 required. Lender approved exception.

Residual income required $6,600, actual $12,641.82; Difference $6,041.83. (5) Dependents. Required 9 months; borrower has 35 months with remaining net 401k. Maximum allowed 50.000%; borrower's DTI 38,796%.

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191229

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.77630% or Final Disclosure APR of 6.77600% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

D

B

201191229

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201191229

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $2.44 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Reviewer Comment (2017-01-20): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2017-01-10): While paid by the seller, CDA is traditionally a buyer paid fee and should be disclosed accordingly.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201191229

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

37% DTI on this full documentation loan < 50% guideline max - 13% below program guideline maximum

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

D

B

201191229

Compliance

Compliance

Federal Compliance

TRID - the file contains an illegible TRID disclosure. Testing is incomplete

contains an incomplete closing disclosure.

Reviewer Comment (2017-01-18): Received attestation that disclosure was produced by title and never presented to borrower.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

A

D

A

D

A

D

A

D

A

Higher Priced QM

Higher Priced QM

Yes

D

B

201191229

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201191230

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income required is $5,650 and actual is $9,143.47. Need 3 months of reserves and have 7 months. Fico of 708 allows max ltv 90%.

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191230

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191230

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Residual income required is $5,650 and actual is $9,143.47. Need 3 months of reserves and have 7 months. Fico of 708 allows max ltv 90%.

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191230

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-10): All guidelines violations have been addressed by lender.

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201191230

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-10): All guidelines violations have been addressed by lender.

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201191231

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower has a retirement account with a balance of $41,365.12, however due to the borrower's age, the guidelines do not allow to use for reserves. 701 representative FICO score > 660 guideline minimum - 41 points above guideline minimum 80% LTV < 90% guideline max

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191231

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.01260% or Final Disclosure APR of 7.04800% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

APR on subject loan of 7.01260% or Final Disclosure APR of 7.04800% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%. Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201191231

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-01-09): File switched to Non-QM

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201191231

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Closing disclosure did not indicate any seller fees vs the Sellers Closing disclosure that had $12,114.88 in fees.

Reviewer Comment (2017-01-25): Data correct on subsequent CDs (SFIG).

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201191231

Compliance

Compliance

Federal Compliance

QM Points and Fees

Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of 3.80252% is in excess of the allowable maximum of  3.00000% of the Federal Total Loan Amount. Points and Fees total $5,155.00 on a Federal Total Loan Amount of $135,567.90 vs. an allowable total of $4,067.03 (an overage of $1,087.97 or .80252%).

Reviewer Comment (2017-01-09): File switched to Non-QM

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

If a creditor or assignee determines after consummation that the total points and fees exceeds the 3% limit, but the loan meets the other requirements to be a QM, the excess amount can be refunded with the following conditions: 1) The refund is made within 210 days of consummation; 2) The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit; 3) The loan is not 60 days delinquent; 4) The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments). The lender will also be required to provide a copy of the refund check and proof of delivery.

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201191232

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

45% DTI on this full documentation loan < 50% guideline max - 5% below program guideline maximum

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191232

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.20130% or Final Disclosure APR of 7.20100% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

Note rate 7.375%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201191232

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $14,034.28, final CD shows $179,976.19.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191232

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-01-06): This is cured at settlement.

01/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201191232

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-01-11): Received evidence that borrower received disclosure within timing requirements.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201191233

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved DTI exception to 52% however SE  income calculated with "Business Use of Home" deduction added in that is not shown on borrowers tax return.  As well, they did not consider non occupying co borrowers space expense on mobile home for  .  Therefore, DTI is higher than approved.

80% LTV < 90% guideline max 13 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-18): Client elects to waive. Reviewer Comment (2017-01-13): Income mislabeled as Business Use of Home was actually from mileage driven, which has been added to income.  DTI is now 55%, which is still higher than waiver approval.  Appears lender used $663 for consumer debt; however, per credit report, consumer debt = $1299.  Lender omitted a [REDACTED] debt but unable to determine why, Reviewer Comment (2017-01-13): Income mislabeled as Business Use of Home was actually from mileage driven, which has been added to income.  DTI is now 55%, which is still higher than waiver approval.  Appears lender used $663 for consumer debt; however, per credit report, consumer debt = $1299, which is supported by 1003s.

01/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191233

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

80% LTV < 90% guideline max 13 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-09): Client elects to waive.

01/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201191233

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-18): All guidelines violations have been addressed by lender.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201191233

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-18): All guidelines violations have been addressed by lender.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201191233

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.28710% or Final Disclosure APR of 6.28700% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201191233

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201191233

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.28710% or Final Disclosure APR of 6.28700% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-01-18): All guidelines violations have been addressed by lender.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201191233

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-01-18): All guidelines violations have been addressed by lender.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201191233

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $38.52 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-01-09): Cured at closing.

01/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201191233

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.28710% or Final Disclosure APR of 6.28700% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201224875

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

42% DTI on this full documentation loan < 50% guideline max - 8% below program guideline maximum

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201224875

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Final closing disclosure reflects seller paid fees of $415,591.68.  Seller closing Disclosure reflects seller paid fees of $11,281.57.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201224875

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Guidelines required 9 months PITIA reserves. Reserve requirement was not met.  Verified 7.87 months reserves.

Reviewer Comment (2017-01-31): Received access letter.  No violation. Reviewer Comment (2017-01-18): An access letter from spouse will be required to consider 100% of statement balance in reserve calculations.

01/31/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201224875

Credit

Credit

Misc

Credit Exception:

Borrower is 50% owner of a S-Corp.  Funds from this business account is being used for closing/reserves.  Guidelines require that the borrower provide a letter of explanation which includes an attestation from all other owners of the business that the borrower is entitled to the funds. CPA letter is not sufficient.

Reviewer Comment (2017-01-31): Received required access letter. Reviewer Comment (2017-01-18): An access letter from spouse will be required to consider 100% of statement balance in reserve calculations.

01/31/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201224875

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Lender used  per month for taxes, actual amount is $

Reviewer Comment (2017-02-01): File switched to Non-QM.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201224875

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Reviewer Comment (2017-02-01): File switched to Non-QM

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201224876

Compliance

Compliance

State Compliance

North Carolina Rate Spread Threshold Test

North Carolina Rate Spread Home Loan: APR on subject loan of 6.95290% or Final Disclosure APR of 6.95300% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Rate Spread Home Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201224876

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Reviewer Comment (2017-02-03): Received all required asset documentation. Reviewer Comment (2017-01-25): Missing evidence of EMD receipt by title.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201224876

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved Exception

Borrower on this full documentation loan has residual income of $6040 > required $3880 Has 42 months housing history > required 12 months Borrower has other income of approximately $108 per month which was not used for qualifying income.

Reviewer Comment (2017-01-10): Client elects to waive.

01/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201224876

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

CDA Fee charged on CD but no report provided.

Borrower on this full documentation loan has residual income of $6040 > required $3880 Has 42 months housing history > required 12 months Borrower has other income of approximately $108 per month which was not used for qualifying income.

Reviewer Comment (2017-01-25): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201224876

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Reviewer Comment (2017-01-12): Received copy of fraud report.

01/12/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201224876

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.95290% or Final Disclosure APR of 6.95300% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-01-10): All guidelines violations have been addressed by lender

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201224876

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-01-10): All guidelines violations have been addressed by lender

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201224876

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-10): All guidelines violations have been addressed by lender

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201224876

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-01-10): All guidelines violations have been addressed by lender

01/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201224876

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.95290% or Final Disclosure APR of 6.95300% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201224877

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

8.36 months of reserves when only 3 months are required for Rate and Term Refi. DTI of 32.584% is significantly below 43%.

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201224877

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.96530% or Final Disclosure APR of 6.96500% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.875%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201224877

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

Last LE shows Title - Notary Fees, CD shows Title - Mobile Notary Fee.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201224877

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $60.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75197)

Reviewer Comment (2017-01-11): This was cured at settlement.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

Yes

C

B

201224877

Credit

Credit

Misc

Credit Exception:

Significant Derog event on property that was included in Ch 7 BK but has not been completed.

8.36 months of reserves when only 3 months are required for Rate and Term Refi. DTI of 32.584% is significantly below 43%.

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201224877

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

A

A

A

A

A

Higher Priced QM

Non QM

Yes

C

B

201224877

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

QM qualification requires the use of the maximum rate in the first 5 years method.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201224877

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201224878

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee charged on CD but no report provided.

716 representative FICO score > 660 guideline minimum - 56 points above guideline minimum

Reviewer Comment (2017-01-20): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201224878

Compliance

Compliance

Federal Compliance

Sole Proprietorship Income Documentation

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Sole Proprietorship).

Missing Balance Sheet.

Reviewer Comment (2017-01-18): Received all required income documentation.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201224878

Compliance

Compliance

Federal Compliance

Sole Proprietorship Income Documentation

Qualified Mortgage (Dodd-Frank 2014): Self-employed income documentation not sufficient (Sole Proprietorship).

Missing Balance Sheet.

Reviewer Comment (2017-01-18): Received all required income documentation.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201224878

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-01-18): Received all required income documentation. Reviewer Comment (2017-01-17): Designation discrepancy is due to missing income documentation.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224878

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.74290% or Final Disclosure APR of 6.74300% is in excess of allowable threshold of APOR 3.50% + 2.5%, or 6.00000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201224878

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.74290% or Final Disclosure APR of 6.74300% is in excess of allowable threshold of APOR 3.50% + 2.5%, or 6.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201224879

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

58% LTV < 80% guideline max

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201224879

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.98980% or Final Disclosure APR of 6.99000% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.875%,

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201224880

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

58% LTV < 80% guideline max

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201224880

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

Seller Closing Disclosure was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201224880

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201224881

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Paid Other Costs Total Section E

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed Total Taxes and Other Government Fees (Section E) that does not match sum of fees. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224881

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA (2010): Initial escrow account statement does not match charges on Final Closing Disclosure.

The combined tax and insurance amount disclosed on the Initial Escrow Account Disclosure Statement shows as $. The combined amount per the CD totals $. Note: The lender used the tax amount based on vacant land. Review used the improved value amount of $ monthly per the Tax Cert provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201224881

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Borrower Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Borrower at Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

The CD reflects $, the correct amount should be $. Note: This appears to be an addition error as all fees cents are even amounts.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224881

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/118488)

Lender based tax amount off unimproved land. The tax cert used in review is based on improved land.

Reviewer Comment (2017-03-16): Data correct on subsequent CDs (SFIG).

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224881

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/118489)

Lender based tax amount off unimproved land. The tax cert used in review is based on improved land.

Reviewer Comment (2017-03-16): Data correct on subsequent CDs (SFIG).

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224881

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/118490)

Lender based tax amount off unimproved land. The tax cert used in review is based on improved land.

Reviewer Comment (2017-03-16): Data correct on subsequent CDs (SFIG).

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224881

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/118491)

Lender based tax amount off unimproved land. The tax cert used in review is based on improved land.

Reviewer Comment (2017-03-16): Data correct on subsequent CDs (SFIG).

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224881

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/118488)

Lender based tax amount off unimproved land. The tax cert used in review is based on improved land.

Reviewer Comment (2017-03-16): Data correct on subsequent CDs (SFIG).

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224881

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $13.501.89, the final CD shows $29,206.98.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224881

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.92840% or Final Disclosure APR of 5.92800% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201224881

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-01-19): Received evidence that ARM disclosure provided when program changed.

01/19/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201224881

Credit

Credit

Misc

Credit Exception:

Missing source of  EMD .  Appears to be from business account, however bank statement not provided verifying.

Reviewer Comment (2017-02-01): Received evidence of an acceptable EMD source.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201224882

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

B

B

201224883

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.57880% or Final Disclosure APR of 8.57900% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 8.50%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201224883

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $250.00 exceeds tolerance of $180.00 plus 10% or $198.00.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2017-01-11): Cured at closing.  $50 reconveyance fee (verified through final settlement statement) was paid by seller and isn't part of testing.  Cure amount sufficient for violation.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224884

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

37.5% DTI on this full documentation loan < 43% guideline max Borrower has excess residual income of $10,559.56 > $2,300 Borrower has bonus income in the amount of $9,607 per month that is not being used in qualification

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201224884

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.07130% or Final Disclosure APR of 8.07100% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 8.00%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201224884

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-25): Data correct on subsequent CDs (SFIG).

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224884

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $461.25 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Fee was not disclosed on Loan Estimate. No valid changed circumstances disclosure provided.

Reviewer Comment (2017-01-25): Received VCCs and LEs for all fee discrepancies.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224884

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $855.00 exceeds tolerance of $595.00.  Insufficent or no cure was provided to the borrower. (73196)

Fee disclosed as $595.00 on the LE, but disclosed as $855.00 on Final Closing Disclosure. No valid changed circumstances disclosure provided.

Reviewer Comment (2017-01-25): Received VCC for increase.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224884

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee was not disclosed on Loan Estimate. No valid changed circumstances disclosure provided.

Reviewer Comment (2017-01-25): Received VCCs and LEs for all fee discrepancies.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224884

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee.  Fee Amount of $540.00 exceeds tolerance of $400.00.  Insufficent or no cure was provided to the borrower. (7561)

Fee disclosed as $400.00 on the LE, but disclosed as $540.00 on Final Closing Disclosure. No valid changed circumstances disclosure provided.

Reviewer Comment (2017-01-25): Received VCCs and LEs for allReceived VCCs and LEs for all fee discrepancies. fee discrepancies.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224884

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Examination Fee.  Fee Amount of $195.00 exceeds tolerance of $185.00.  Insufficent or no cure was provided to the borrower. (7565)

Fee disclosed as $185.00 on the LE, but disclosed as $195.00 on Final Closing Disclosure. No valid changed circumstances disclosure provided.

Reviewer Comment (2017-01-25): Received VCCs and LEs for all fee discrepancies.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224884

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure of $328.20 was reflected, which is insufficient to cure $1,021.25. $693.05 remains to be cured.

Reviewer Comment (2017-01-25): Received VCCs and LEs for all fee discrepancies.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224884

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

37.5% DTI on this full documentation loan < 43% guideline max Borrower has excess residual income of $10,559.56 > $2,300 Borrower has bonus income in the amount of $9,607 per month that is not being used in qualification

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201224884

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

Reviewer Comment (2017-01-25): Cured at closing.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224885

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.24010% or Final Disclosure APR of 6.24000% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201224885

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

No E sign Disclosure present

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

B

B

201224886

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

61% LTV < 80% guideline max

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201224886

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $12,983.81, final CD shows $14,333.81.Administration Fee in the amount of $1,350 paid by seller was not reflected on Sellers CD.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201224886

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

No violation - cure provided on Closing Disclosure

Reviewer Comment (2017-01-11): Cured at settlement.

01/11/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201224887

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $58,592.99, final CD shows $59,926.49

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201224888

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Reviewer Comment (2017-01-13): Received copy of executed Note.

01/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

D

A

D

A

D

A

D

A

D

A

Higher Priced QM

Higher Priced QM

No

D

B

201224888

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

23% DTI on this full documentation loan < 43% guideline max - 20% below program guideline maximum

Reviewer Comment (2017-01-11): Client elects to waive.

01/11/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

D

B

201224888

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.24570% or Final Disclosure APR of 6.24500% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

D

B

201224888

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201224888

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Cure provided on Closing Disclosure

Reviewer Comment (2017-01-11): Cured at settlement.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

D

B

201224888

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

TILA-RESPA Integrated Disclosure: Settlement Service Provider List did not provide at least one available provider for each settlement service borrower is entitled to shop for or inform borrower they may choose different provider from list.

Missing the SSPL. Only an acknowledgement of receipt was provided.

Reviewer Comment (2017-01-13): Received evidence that borrower received disclosure within timing requirements.

01/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

No

D

B

201224888

Credit

Credit

Misc

Credit Exception:

Missing copy of SSPL to complete TRID testing.

Reviewer Comment (2017-01-13): Received evidence that borrower received disclosure within timing requirements.

01/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

D

B

201225647

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

36% DTI on this full documentation loan < 43% guideline max - 7% below program guideline maximum

Reviewer Comment (2017-01-12): Client elects to waive.

01/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201225647

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.39290% or Final Disclosure APR of 7.42600% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.25%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201225647

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a negative fee amount. (Final/[MM/DD/YYYY])

Disclosure reflects a negative fee for Title - Owner's Title Insurance (Optional) in Section H.  This is TRID non-compliant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201225647

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose number of months for Property Tax under Prepaids. (Final/[MM/DD/YYYY])

Number of months is not indicated.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201225647

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $20,876.75, final CD shows $20,655.75.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201225647

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $258.00 exceeds tolerance of $225.00 plus 10% or $247.50.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-01-12): Cured at closing.

01/12/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201225647

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $775.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-01-12): Cured at closing.

01/12/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201228454

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.11000% or Final Disclosure APR of 6.11000% is in excess of allowable threshold of APOR 3.58% + 1.5%, or 5.08000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201228454

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure  [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-01-19): Data correct on subsequent CDs (SFIG).

01/19/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201228456

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee was charged but no report provided.

72% LTV < 80% guideline max

Reviewer Comment (2017-01-20): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

No

C

B

201228456

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.85830% or Final Disclosure APR of 6.85800% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.75%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201228456

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.85830% or Final Disclosure APR of 6.85800% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Loan.

Note rate is 6.75%

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

No

C

B

201228456

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final Closing Disclosure reflects a closing date of [MM/DD/YYYY] and the mortgage notary reflects a signing date of [MM/DD/YYYY]. Note: This is not corrected on the post funding CD.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201228456

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-13): Designation switched to Rebuttable Presumption.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201228457

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

656 > required 620

Reviewer Comment (2017-01-12): Client elects to waive.

01/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201228457

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $85.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-01-11): This was cured at settlement.

01/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201228457

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.49280% or Final Disclosure APR of 7.49300% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.125%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201228458

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee was charged  but no report was provided.

16 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-25): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201228458

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.86770% or Final Disclosure APR of 8.86800% is in excess of allowable threshold of APOR 4.12% + 1.5%, or 5.62000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201228458

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-13): Received evidence that borrower received disclosure within timing requirements.

01/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201228458

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201228458

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $43.73 exceeds tolerance of $35.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Cure provided on Closing DIsclosure

Reviewer Comment (2017-01-25): Cured at closing.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201231605

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.92060% or Final Disclosure APR of 6.94400% is in excess of allowable threshold of APOR 3.98% + 2.5%, or 6.48000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.875%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

D

B

201231605

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $72,075.14, final CD shows $79,500.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201231605

Compliance

Compliance

Federal Compliance

TRID - the file contains an illegible TRID disclosure. Testing is incomplete

Post closing CD's from [MM/DD/YYYY] at pages are missing page 5.

Reviewer Comment (2017-02-07): Received full copy of disclosure. Reviewer Comment (2017-02-01): Still unable to locate page 5 from 12/30 CD. Reviewer Comment (2017-01-26): Received rebuttal document, however page 5 from the 12/30 CD was not included.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

A

D

A

D

A

D

A

D

A

Non QM

Non QM

Yes

D

B

201231605

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Late Payment Test

TILA-RESPA Integrated Disclosure- Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the terms of the Late Payment. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-12): This is cured on the [MM/DD/YYYY] post funding CD.

01/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201231605

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Credit score of 644 is less than required 660. Lender approved this exception.

The residual income, $10,391, is above the required amount of $8,750. The reserves of 38 months are above the required reserves of 6 months.

Reviewer Comment (2017-01-19): Client elects to waive.

01/19/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201233626

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.46480% or Final Disclosure APR of 8.46500% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 8.00%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201233626

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Shown to be $60.25. Documentation supports a monthly amount of $60.75.

Reviewer Comment (2017-01-30): Data correct on subsequent CDs (SFIG).

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201233626

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on  [MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Field is blank. This field requires a numeric entry.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201233626

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201233626

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/123869)

Section G Homeowner's Insurance monthly premium shown as $60.25. This supports an annual premium of $723.00. Documentation and annual premium in section F support an annual premium of $729.00 which is a monthly premium of $60.75.

Reviewer Comment (2017-01-30): Data correct on subsequent CDs (SFIG).

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201233626

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/123870)

Section G Homeowner's Insurance monthly premium shown as $60.25. This supports an annual premium of $723.00. Documentation and annual premium in section F support an annual premium of $729.00 which is a monthly premium of $60.75.

Reviewer Comment (2017-01-30): Data correct on subsequent CDs (SFIG).

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201233626

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/123871)

Section G Homeowner's Insurance monthly premium shown as $60.25. This supports an annual premium of $723.00. Documentation and annual premium in section F support an annual premium of $729.00 which is a monthly premium of $60.75.

Reviewer Comment (2017-01-30): Data correct on subsequent CDs (SFIG).

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201233626

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/123872)

Section G Homeowner's Insurance monthly premium shown as $60.25. This supports an annual premium of $723.00. Documentation and annual premium in section F support an annual premium of $729.00 which is a monthly premium of $60.75.

Reviewer Comment (2017-01-30): Data correct on subsequent CDs (SFIG).

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201233626

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/123869)

Section G Homeowner's Insurance monthly premium shown as $60.25. This supports an annual premium of $723.00. Documentation and annual premium in section F support an annual premium of $729.00 which is a monthly premium of $60.75.

Reviewer Comment (2017-01-30): Data correct on subsequent CDs (SFIG).

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201233627

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

55 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201233627

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.10260% or Final Disclosure APR of 6.10300% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201233627

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201233627

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.10260% or Final Disclosure APR of 6.10300% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201233627

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-01-18): Received evidence that disclosure provided within 3 days of program change.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201233628

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.11170% or Final Disclosure APR of 6.11200% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201233628

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.11170% or Final Disclosure APR of 6.11200% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201233628

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201233628

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual Income; Minimum $3050; Actual $5671.41 Reserves; Actual 6 mos. Requirement 3 mos. LTV;  Maximum 90%; Actual 75% Mortgage payment history; consistently on time.

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201233628

Credit

Credit

Misc

Credit Exception:

DTI exception up to 53% when the max DTI allowed is 50%.

Residual Income; Minimum $3050; Actual $5671.41 Reserves; Actual 6 mos. Requirement 3 mos. LTV;  Maximum 90%; Actual 75% Mortgage payment history; consistently on time.

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201233629

Credit

Loan Package Documentation

Closing / Title

Title: Evidence of title is missing

Reviewer Comment (2017-02-01): Received copy of title.

02/01/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201233629

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201233629

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/123866)

Reviewer Comment (2017-01-30): Escrow accounts are accurate.

01/30/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201233629

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/123866)

Reviewer Comment (2017-01-30): Escrow accounts are accurate.

01/30/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201233629

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201233629

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

44% LTV < 70% guideline max

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201233630

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

712 representative FICO score > 580 guideline minimum - 132 points above guideline minimum

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201233630

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201233630

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.74240% or Final Disclosure APR of 7.74200% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.50%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201233631

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.92840% or Final Disclosure APR of 7.92600% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.875%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201233631

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $18,860.90, final CD chows $19,210.90.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201233631

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

694 representative FICO score > 620 guideline minimum - 74 points above guideline minimum

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201233632

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.72840% or Final Disclosure APR of 6.72800% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.75%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201233632

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $7,735.47, final CD shows $113,499.65.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201233632

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

735 representative FICO score > 660 guideline minimum - 75 points above guideline minimum

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

B

B

201236082

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.59970% or Final Disclosure APR of 6.60000% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201236082

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 6.59970% or Final Disclosure APR of 6.60000% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

B

B

201236083

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.21870% or Final Disclosure APR of 6.21900% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 5.625%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201236083

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.21870% or Final Disclosure APR of 6.21900% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Loan.

Note rate is 5.625%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201236083

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

$4,020.00 shortfall. File is missing documentation for a lower replacement cost..

Reviewer Comment (2017-01-18): Received Estimated Replacement Cost value from insurance company.  Coverage is sufficient.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201236083

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

19 months reserves > 6 months guideline minimum - borrowers have verified reserves of $63,387.51 Borrower has owned the subject property for 17 years with 125 months satisfactory payments until 10/16 Spouse not on loan additional income of $70,000 documented in file

Reviewer Comment (2017-01-17): Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236083

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $475.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-01-17): Cured at closing.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201236083

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

19 months reserves > 6 months guideline minimum - borrowers have verified reserves of $63,387.51 Borrower has owned the subject property for 17 years with 125 months satisfactory payments until 10/16 Spouse not on loan additional income of $70,000 documented in file

Reviewer Comment (2017-01-17): Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236084

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

12 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-25): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

D

B

201236084

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.08400% or Final Disclosure APR of 7.08400% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

D

B

201236084

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on  [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

An Assessment Search Fee was added in section C which disrupted the order.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201236084

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Disclosure Disclosed $18,365.93 in seller paid fees vs the Final Closing Disclosure Disclosed $81,355.10 which included the sellers 1st and 2nd lien payoff.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201236084

Compliance

Compliance

Federal Compliance

TRID - the file contains an illegible TRID disclosure. Testing is incomplete

are incomplete closing disclosures.

Reviewer Comment (2017-01-19): Received attestation that disclosure was produced by title and never presented to borrower.

01/19/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

A

D

A

D

A

D

A

D

A

Higher Priced QM

Higher Priced QM

Yes

D

B

201236085

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.73770% or Final Disclosure APR of 6.73800% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.375%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201236085

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

24% DTI on this full documentation loan < 50% guideline max - 26% below program guideline maximum

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201236085

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA (2010): Initial escrow account statement does not match charges on Final Closing Disclosure.

The Initial Escrow Account Disclosure Statement shows a monthly payment amount of $. The final CD and support documentation support a payment of $.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201236085

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $1,000.33, Final CD shows $398,693.86.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201236085

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as $90.00 on all LE's, but disclosed as $92.00 on Final Closing Disclosure.

Reviewer Comment (2017-01-13): This was cured on the final CD.

01/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201236086

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

22 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-13): Client elects to waive.

01/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236086

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.98400% or Final Disclosure APR of 8.98400% is in excess of allowable threshold of APOR 4.12% + 1.5%, or 5.62000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201236087

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.54790% or Final Disclosure APR of 7.54800% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201236087

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201236087

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

38% DTI on this full documentation loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2017-01-17): Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236087

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $131.14 exceeds tolerance of $100.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-01-16): Credit provided art closing of $33.14 to cover this and one other fee.

01/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201236087

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-01-16): $33.14 credit provided at closing to cover this fee and one other.

01/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201236206

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

70% LTV < 80% guideline max

Reviewer Comment (2017-01-17): Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236206

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $8.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7579)

Cure provided on Closing Disclosure

Reviewer Comment (2017-01-17): Cured at closing.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201236206

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Cure provided on Closing Disclosure

Reviewer Comment (2017-01-17): Cured at closing.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201236206

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.55220% or Final Disclosure APR of 8.55200% is in excess of allowable threshold of APOR 2.90% + 1.5%, or 4.40000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201236206

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-01-25): Received evidence that borrower received disclosure within timing requirements.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201236207

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower has an additional 14 months of reserves on top of the 9 months reserves required on HOA program at 90% LTV. Borrower is providing an additional 12 months of payment history showing 0x30 in the past 24 months.

Reviewer Comment (2017-01-17): Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236207

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201236207

Credit

Credit

Misc

Credit Exception:

LTV exception from 85% to 90%  with borrower fico of 679.

Borrower has an additional 14 months of reserves on top of the 9 months reserves required on HOA program at 90% LTV. Borrower is providing an additional 12 months of payment history showing 0x30 in the past 24 months.

Reviewer Comment (2017-01-17): Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236207

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.07440% or Final Disclosure APR of 7.08000% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201236208

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.40620% or Final Disclosure APR of 6.40600% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201236208

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller -  Cash To Close

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Final Cash to Close that did not match the actual sum of Final cash to close figures. (Final/[MM/DD/YYYY])

Calculation Cash to Close table on Final CD shows -$7,011.87, calculated is -$7,012.25.

Reviewer Comment (2017-02-01): Data correct on subsequent CDs (SFIG). Reviewer Comment (2017-01-26): Received rebuttal, but it does not contain the amounts in the Calculation Cash to Close section.  Please reference this section for the discrepancy.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201236208

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $50.025.30, final CD shows $70,982.72.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201236209

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201236209

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.23160% or Final Disclosure APR of 6.23200% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201236209

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

Reviewer Comment (2017-01-17): Lender gave borrower $150 credit at close.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

B

B

201236210

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.09660% or Final Disclosure APR of 6.09700% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201236210

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201236210

Credit

Credit

Misc

Credit Exception:

DTI at 48% exceeds the 43% max.

Residual income required is $1,000 and the actual is $4,923.55. Bonus income received the last two years and not being included in the effective income.

Reviewer Comment (2017-01-17): Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236210

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.09660% or Final Disclosure APR of 6.09700% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201236210

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income required is $1,000 and the actual is $4,923.55. Bonus income received the last two years and not being included in the effective income.

Reviewer Comment (2017-01-17): Client elects to waive.

01/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201236210

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for National Hazard Disclosure Report.  Fee Amount of $80.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75142)

Reviewer Comment (2017-01-17): Cured at closing.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201236210

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-01-17): Cured at closing.

01/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201238858

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

Final Closing disclosure reflects a finance charge of $888,995.55. Calculated finance charge of 889,795.55. Variance of $800.00.

Reviewer Comment (2017-01-26): $800 attorney fee not considered FC.  No violation.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201238858

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $550.00 exceeds tolerance of $430.00 plus 10% or $473.00.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-01-19): Cure of $99.00 on final closing disclosure.

01/19/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201238858

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.02280% or Final Disclosure APR of 8.00700% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201238858

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller closing disclosure reflects seller paid costs of $3,431.00. Final closing disclosure reflects seller paid fees of $6,507.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201238859

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Section F. Discloses 12 mo Premium of $495.48, however the actual amount is $1,979.04.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201238859

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Exceeded the Legal Limit by $150.00

Reviewer Comment (2017-01-25): Desk Review Fee was on initial LE.  No violation.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201238859

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.41730% or Final Disclosure APR of 8.42000% is in excess of allowable threshold of APOR 4.20% + 2.5%, or 6.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201238859

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7505)

Reviewer Comment (2017-01-25): Desk Review Fee was on initial LE.  No violation.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201238859

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

CDA in file is stale dated.  Missing updated CDA to confirm 442 value.

Reviewer Comment (2017-02-01): Received updated CDA that supports value.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201238860

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

6 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-20): Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201238860

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-20): Received evidence that borrower received disclosure within timing requirements.

01/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201238860

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $200.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75103)

Appraisal Re-inspection fee was not disclosed on Loan Estimate.

Reviewer Comment (2017-01-18): Cure for $200 reflected on final closing disclosure.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201238860

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $85.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Tax Service Fee disclosed as $85.00 on LE dated [MM/DD/YYYY], but disclosed as $92.00 on Final Closing Disclosure.

Reviewer Comment (2017-01-18): Cure for $7.00 reflected on final closing disclosure.

01/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201238861

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2017-01-19): Initial LE allowed on brokered loans.

01/19/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201238861

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-01-26): VCC provided

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201238861

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $6,516.00 exceeds tolerance of $6,269.00.  Insufficent or no cure was provided to the borrower. (7200)

No VCC provided.

Reviewer Comment (2017-01-26): VCC provided

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201238861

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $77.80 exceeds tolerance of $70.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-01-18): Lender provided $7.80 credit at closing.

01/18/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201238861

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

716 representative FICO score > 660 guideline minimum - 56 points above guideline minimum

Reviewer Comment (2017-01-19): Client elects to waive.

01/19/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201238861

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $77.80 exceeds tolerance of $70.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-01-26): Cured at closing.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201239627

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report supplied.

Reviewer Comment (2017-01-26): Received copy of desk review.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201239627

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-01-25): 2106 Expenses removed from DTI calcs.  Borrower is not commissioned nor has an automobile allowance.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201239627

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Appears lender did not inlcude Schedule A deductions in DTI calculations.

Reviewer Comment (2017-01-25): 2106 Expenses removed from DTI calcs.  Borrower is not commissioned nor has an automobile allowance.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201239627

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 9.94720% or Final Disclosure APR of 9.94700% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201239627

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Closing Disclosure Issue Date([MM/DD/YYYY]) > Closing Date Less 6([MM/DD/YYYY]) AND ( Closing Disclosure Received Date([MM/DD/YYYY]) IS NOT NULL AND Closing Disclosure Received Date([MM/DD/YYYY]) > Closing Date Less 3([MM/DD/YYYY]) )

Reviewer Comment (2017-01-25): Received evidence that borrower received disclosure within timing requirements.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201239627

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on  [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Loan Estimate Received Date([MM/DD/YYYY]) >= Closing Date Less 3([MM/DD/YYYY])

Reviewer Comment (2017-01-25): Received evidence that borrower received disclosure within timing requirements.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201239627

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender Approved Exception

45% LTV < 80% guideline max Borrower on this full documentation loan has residual income of $3,207.00 > minimum required of $1,557.00

Reviewer Comment (2017-01-20): Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201239627

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.94720% or Final Disclosure APR of 9.94700% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201239628

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

27% DTI on this full documentation loan < 50% guideline max - 23% below program guideline maximum

Reviewer Comment (2017-01-20): Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201239628

Compliance

Compliance

Federal Compliance

QM Employment History

Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.

Reviewer Comment (2017-02-03): Received all required income documentation. Reviewer Comment (2017-01-30): Received 2013 W2s.  Please provide VOEs to verify dates of employment. Reviewer Comment (2017-01-20): When returning to work after an extended absence, a 2 year history PRIOR to the gap must be provided.  File only contains 22 months prior work history.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201239628

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-03): Received all required income documentation.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201239628

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201239628

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201239628

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $100.51 exceeds tolerance of $100.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Cure provided on Closing Disclosure

Reviewer Comment (2017-01-20): Cured at closing.

01/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201239628

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on[MM/DD/YYYY], prior to three (3) business days from transaction date of  [MM/DD/YYYY].

Reviewer Comment (2017-01-25): Data correct on subsequent CDs (SFIG).

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201239628

Credit

Loan Package Documentation

Closing / Title

Note Error: Street address is blank.

Reviewer Comment (2017-01-25): Note has legal address.  No violation.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201239628

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Initial Loan Estimate differs

Reviewer Comment (2017-01-20): Allowed on brokered loans.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201239629

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34% DTI on this full documentation loan < 50% guideline max - 16% below program guideline maximum

Reviewer Comment (2017-01-20): Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201239629

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.73170% or Final Disclosure APR of 6.73200% is in excess of allowable threshold of APOR 3.50% + 2.5%, or 6.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201239629

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.73170% or Final Disclosure APR of 6.73200% is in excess of allowable threshold of APOR 3.50% + 2.5%, or 6.00000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201239629

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201239629

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-1,730.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,870.00. (9300)

Reviewer Comment (2017-01-26): Received valid CoC regarding lender credit reduction.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201239629

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201239629

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $600.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2017-01-20): Lender provided $50 credit at closing.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201239630

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

45% DTI on this full documentation loan < 50% guideline max - 5% below program guideline maximum

Reviewer Comment (2017-01-20): Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201239630

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.22800% or Final Disclosure APR of 6.22800% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Loan.

Note rate is 6.125%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201239630

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller at Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

Lender included the Seller Paid fee Before Closing in the at closing total.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201239630

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - Before Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller Before Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

Lender included the Seller Paid fee Before Closing in the at closing total.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201239630

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY]. Note: This is not corrected on the post closing CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201239630

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $40,337.92, final CD shows $670,602.92.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201239630

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-01-19): This is cured at settlement.

01/19/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201239630

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.22800% or Final Disclosure APR of 6.22800% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201239631

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residuals in excess of $1891.89/month. Required: $3700/month Actual: 5681.89/month Income not reflected in Effective Income. Borrower spouse (non-borrowing) received monthly $597/month. (Evidence of current receipt is within loan file; U/W has requested last 2 years 1099's). On time housing payment history above and beyond program requirements. Borrower has 24 months on time housing payment history when 12 months pymt history is required.

Reviewer Comment (2017-01-20): Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201239631

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

51.47189% DTI exceeds program maximum of 50.00%. Lender approved exception.

Residuals in excess of $1891.89/month. Required: $3700/month Actual: 5681.89/month Income not reflected in Effective Income. Borrower spouse (non-borrowing) received monthly $597/month. (Evidence of current receipt is within loan file; U/W has requested last 2 years 1099's). On time housing payment history above and beyond program requirements. Borrower has 24 months on time housing payment history when 12 months pymt history is required.

Reviewer Comment (2017-01-20): Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201239631

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.92820% or Final Disclosure APR of 6.92800% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Non-Compliant Higher Priced Mortgage Loan.

Note rate is 6.875%.

Reviewer Comment (2017-01-20): All guidelines violations have been addressed by lender.

01/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201239631

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Lender approved DTI to 52.00%

Reviewer Comment (2017-01-20): All guidelines violations have been addressed by lender.

01/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201239631

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Lender approved DTI to 52.00%

Reviewer Comment (2017-01-20): All guidelines violations have been addressed by lender.

01/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201239631

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Lender approved DTI to 52.00%

Reviewer Comment (2017-01-20): All guidelines violations have been addressed by lender.

01/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201239631

Compliance

Compliance

Federal Compliance

RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure

RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201239631

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $1,858.00, final CD shows $624,505.75.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201239631

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.92820% or Final Disclosure APR of 6.92800% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201239632

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee was collected but no report provided.

12 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-30): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201239632

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201239632

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.15770% or Final Disclosure APR of 6.15800% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201239633

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

50 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-20): Client elects to waive.

01/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201239633

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.49780% or Final Disclosure APR of 6.49800% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201239633

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.49780% or Final Disclosure APR of 6.49800% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Loan.

Note rate is 6.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201239633

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA (2010): Initial escrow account statement does not match charges on Final Closing Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201239633

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201244772

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.89880% or Final Disclosure APR of 6.89900% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201244772

Compliance

Compliance

State Compliance

Maryland Counseling Agencies Disclosure Not in File

Maryland HB1399 - No evidence of counseling agencies list per Maryland HB 1399.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201244772

Compliance

Compliance

State Compliance

(State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided)

Maryland Higher-Priced Mortgage Loan:  Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for.

Reviewer Comment (2017-01-26): Received evidence that disclosure was presented at closing.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201244772

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 6.89880% or Final Disclosure APR of 6.89900% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201244772

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2017-01-24): Initial LE used with seller form, all subsequent LE's and CD's used without seller form.

01/24/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201244772

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Section F shows 12 months HOI premium of $2,472.00 or $206.00 per month. Section G shows monthly escrow payment of $289.42.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201244772

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-01-24): Lender provided $569.30 credit at closing for increase in Closing Costs above legal limit.

01/24/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201244772

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $117.30 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-01-24): Lender provided $569.30 credit at closing for increase in Closing Costs above legal limit.

01/24/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201244772

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-01-24): Lender provided $569.30 credit at closing for increase in Closing Costs above legal limit.

01/24/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201244772

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Document Preparation Fee.  Fee Amount of $220.00 exceeds tolerance of $150.00.  Sufficient or excess cure was provided to the borrower at Closing. (7725)

Reviewer Comment (2017-01-24): Lender provided $569.30 credit at closing for increase in Closing Costs above legal limit.

01/24/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201244772

Credit

Credit

Misc

Credit Exception:

Short Sale is less than 2 years from application.  Not allowed on Tier 2 product.

24% DTI on this full documentation loan < 50% guideline max - 26% below program guideline maximum

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201244772

Compliance

Compliance

Miscellaneous Compliance

Initial TIL not provided

CDA provided is stale dated.  Updated CDA validating appraised value required.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201244772

Compliance

Compliance

State Compliance

(State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided Timely)

Maryland Higher-Priced Mortgage Loan: Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for prior to closing.

Reviewer Comment (2017-03-10): Received attestation from lender that no non-HPML loans were available for the borrower at the time of submission. t

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201244773

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.17400% or Final Disclosure APR of 8.26000% is in excess of allowable threshold of APOR 3.98% + 1.5%, or 5.48000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

B

B

201244773

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $19,107.00 and  Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $17,782.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

B

B

201244773

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-27): Designation switched to Rebuttable Presumption.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

B

B

201244774

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller disclosure listed $1,349.50 in Seller Fees vs the Final Closing Disclosure discloses$275.  Re-Disclosure dated [MM/DD/YYYY] Marked as final listed the Total Seller Fees as $192,486.51.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201244774

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final Closing Disclosure disclosed a Closing Date of [MM/DD/YYYY] and the borrower signed on [MM/DD/YYYY].

Reviewer Comment (2017-01-24): Data was corrected on subsequent CD.

01/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201244774

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Annual Hazard Insurance premium is $1,520.71 which reflected in section F, however Section G. Calculation is $125.73 monthly or $1,508.76 annually.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201244774

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.24720% or Final Disclosure APR of 9.26200% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201244774

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 9.24720% or Final Disclosure APR of 9.26200% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201244774

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $25, calculates to be $1750.

Reviewer Comment (2017-02-02): Received VCC regarding discount point.

02/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201244774

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $3,750.00 exceeds tolerance of $2,000.00.  Insufficent or no cure was provided to the borrower. (7200)

Fee disclosed as $2,000 on LE dated 11/1/16 and as $3,750 on Final CD.  Note:  File has a COC which reflects an increase in the discount points and an increase in the interest rate, however no reason was given for the rate increase.

Reviewer Comment (2017-02-02): Received VCC regarding discount point. Reviewer Comment (2017-01-30): Received rebuttal regarding disclaimer and LEs not reflecting locked rate.  However the CoC for the 12/2 LE does not give the reason that the interest rate was raised (program change, LTV, etc).  This is required in order to make sure LE was issued within 3 days of change.

02/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201244775

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this full documentation loan has a residual income of $4522.11 > required residual income of $2300.00 DTI max 50% allowed, DTI 40.29 with payoff of the 2 [REDACTED] auto lease accounts and proof no balance owed for early termination of leases. Current rent is $1800.00 and proposed PITI $2101.34/note rate and $2122.92/qualifying rate - low payment shock of 16.741%

Reviewer Comment (2017-01-24): Client elects to waive.

01/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201244775

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.17280% or Final Disclosure APR of 8.10100% is in excess of allowable threshold of APOR 3.55% + 1.5%, or 5.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201244775

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

Finance charge shown as $344,855.23 and calculated finance charge is $349,766.11. Variance of $4,910.88.

Reviewer Comment (2017-02-07): Received correct index.  No violation.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201244775

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TIP of 162.991% but calculated TIP is 165.352%.  Used Index Value = 1.689% per Loan Transmittal Form document in file.

Reviewer Comment (2017-02-07): Received correct index.  No violation.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201244775

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total of Payments that does not match the actual total of payments for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TOP of $554,550.83 but calculated TOP of $559,461.71.  Variance = $4,910.88.  Used Index Value = 1.689%) per Loan Transmittal Form document in file.

Reviewer Comment (2017-02-07): Received correct index.  No violation.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201244775

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201244775

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-01-30): Received evidence that borrower received disclosure within timing requirements.

01/30/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201244775

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-01-26): Received evidence that borrower received disclosure within timing requirements.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201244775

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender Approved Exception

Borrower on this full documentation loan has a residual income of $4522.11 > required residual income of $2300.00 DTI max 50% allowed, DTI 40.29 with payoff of the 2 [REDACTED] auto lease accounts and proof no balance owed for early termination of leases. Current rent is $1800.00 and proposed PITI $2101.34/note rate and $2122.92/qualifying rate - low payment shock of 16.741%

Reviewer Comment (2017-01-24): Client elects to waive.

01/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201251528

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201251528

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception for exceeding the Maximum DTI for Non-Warrantable Condo Project.

Required residual income required is $1200 per month/actual monthly residual income is $8851.77. Excess monthly residual income $7651.77. 6 months reserves required (3 months for product plus additional 3 months for non-warrantable condo project). Borrowers actual reserves 9.625 months.

Reviewer Comment (2017-01-25): Client elects to waive.

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201251528

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI > 43%, maximum allowed for Non-Warrantable Condos.

Reviewer Comment (2017-01-25): All guidelines violations have been addressed by lender.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201251528

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-25): All guidelines violations have been addressed by lender.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201251529

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this loan has a residual income of $4,588.00 > required $1300.00 28% DTI on this loan < 50% guideline max 70% LTV < 80% guideline max Borrower's rental and primary mortgages are paid

Reviewer Comment (2017-01-25): Client elects to waive.

01/25/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201251529

Compliance

Compliance

Federal Compliance

RESPA  -  Initial Escrow Account Statement Not Provided Timely

RESPA (2010): Initial escrow account statement was not provided to the borrower at closing.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201251529

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-01-26): Received evidence that borrower received disclosure within timing requirements.

01/26/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201251529

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201251529

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201251529

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Lender Approved Exception:  Allowing gift funds on a secondary house purchase

Reviewer Comment (2017-01-26): Exception should have been credit violation, not compliance. Reviewer Comment (2017-01-26): Exception set as compliance rather than credit. Reviewer Comment (2017-01-25): Client elects to waive.

01/26/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201251529

Credit

Credit

Misc

Credit Exception:

Gift funds used on secondary house purchase.

Borrower on this loan has a residual income of $4,588.00 > required $1300.00 28% DTI on this loan < 50% guideline max 70% LTV < 80% guideline max Borrower's rental and primary mortgages are paid

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201251530

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

726 representative FICO score > 660 guideline minimum - 66 points above guideline minimum

Reviewer Comment (2017-01-30): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive. Reviewer Comment (2017-01-25): Fee was collected but no report provided.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201251530

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.24150% or Final Disclosure APR of 7.24200% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201251530

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $16,504.48 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $16,490.48.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201251530

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $8.56 exceeds tolerance of $8.00.  Sufficient or excess cure was provided to the borrower at Closing. (7579)

Reviewer Comment (2017-01-24): Lender gave a $.56 credit at closing.

01/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201251531

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

CD reflects $4,965.94, calculates to be $7,551. ($629.25 x 12)

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201251531

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $644.43.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201251531

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-3,269.01  is less than amount of binding Lender Credit previously disclosed in the amount of $-3,913.00. (9300)

LE dated [MM/DD/YYYY]  reflects $3,913 Lender Credit (Loan was locked) and Final CD reflects $3,269.01 Lender paid fees, a $644.43 reduction in credit.  CD does reflect a $644.43 Lender  balance of credit toward escrow in payoffs and payments.

Reviewer Comment (2017-02-03): Received copy of corrected CD with credit located in correct section.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201251531

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Lender Credit reflected in payoffs and payments should be in section J under Lender Credits.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201251531

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Disclosure signed at closing references a previous waiver.  Borrower did not sign the Waiver on the previous disclosure.  Unable to determine if borrower waived their rights to receipt of appraisal 3 days prior to closing.  There was also no evidence that the copy of the appraisal was provided to the borrower at closing.  The disclosure states the report should have been provided, it does not state that it was provided to the borrower.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201251532

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.34470% or Final Disclosure APR of 6.34500% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201251532

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing disclosure reflects seller paid fees of $21,567.00. Final Closing Disclosure reflects seller paid fees of $191,822.26.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201251532

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on[MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

LE and initial CD reflect $425 Closing/Settlement/Attorney Fees.  Final CD reflects $425 Doc Processing Fee.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201251532

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $4,903.10 exceeds tolerance of $4,378.00 plus 10% or $4,815.80.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-01-25): Cured at closing.

01/25/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

B

B

201251533

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

28% DTI on this full documentation loan < 50% guideline max - 22% below program guideline maximum

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201251533

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.99020% or Final Disclosure APR of 7.99500% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201251533

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201251533

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, caculates to be $483.30.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201251533

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,515.00 exceeds tolerance of $1,847.00 plus 10% or $2,031.70.  Insufficient or no cure was provided to the borrower. (0)

$483.30 violation due to increase in settlement fees and recording charges.  Note:  $596 of settlement fees are seller paid which are included in tolerance testing.  Data is still not accurate on subsequent CD. Post CD dated[MM/DD/YYYY] reflects $229.99 Lender Credit for tolerance cure with a Letter of Explanation, copy of refund check and proof of delivery, however the amount is insufficent to cure the violation..

Reviewer Comment (2017-02-03): Received evidence that fee was to be seller paid per purchase contract.  No violation.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201251533

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Summaries of Transasctions data field is blank, Calculating Cash to Close reflects $0.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201251534

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.56600% or Final Disclosure APR of 8.71900% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201251534

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-02-03): Received evidence that borrower received disclosure within timing requirements

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201251534

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $21,004.59.  Borrower's CD reflects $19,640.59.

Reviewer Comment (2017-01-25): Data is corrected on subsequent CD which reflects $21,004.59 seller paid fees.

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201251534

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-27): Designation switched to Rebuttable Presumption.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201251535

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.07430% or Final Disclosure APR of 7.07800% is in excess of allowable threshold of APOR 4.20% + 2.5%, or 6.70000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201251535

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a negative fee amount. (Final/[MM/DD/YYYY])

Owner's Title Insurance in section H is reflected as -$317.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201251535

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

No

C

B

201251535

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Reviewer Comment (2017-02-21): Lender attests that all red flags have been sufficiently addressed. Reviewer Comment (2017-02-03): Received full report; however, fraud risk is critical.  Red Flags need to be addressed. Reviewer Comment (2017-01-30): Document provided is not a full fraud report.  Only section provided is for property and doesn't contain a risk level analysis.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201251535

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-27): Designation switched to Rebuttable Presumption.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201251536

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.49330% or Final Disclosure APR of 8.51600% is in excess of allowable threshold of APOR 3.98% + 1.5%, or 5.48000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201251536

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $136.00 exceeds tolerance of $40.00 plus 10% or $44.00.  Insufficient or no cure was provided to the borrower. (0)

$72 violatioin.  $20 Deed Recording fee was paid by seller which is customary in the state of Texas.

Reviewer Comment (2017-01-25): Final CD reflects $2937 Lender Credit for tolerance cure.

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201251536

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Origination Fee.  Fee Amount of $2,805.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7325)

Fee not disclosed on LE

Reviewer Comment (2017-01-25): Final CD reflects $2937 Lender Credit for tolerance cure.

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201251536

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $494.00 exceeds tolerance of $434.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee disclosed as $434 on LE dated 11/29 and as $494 on Final CD.

Reviewer Comment (2017-01-25): Final CD reflects $2937 Lender Credit for tolerance cure.

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201251536

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

18 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201251536

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Sreller's CD reflects $17,585.71.  Borrower's CD reflects $11,414.96.

Reviewer Comment (2017-01-25): Data was corrected on subsequent CD which reflects $17,585.71 seller paid fees

01/25/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258959

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $36,999.32.  Borrower's CD reflects $38,132.32.  Data is still not accurate on subsequent CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258959

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

The residual income, $4094, is above the required amount of $3250. The reserves, 8.43 months, are in excess of program requirements of 3 months. The loan to value, 69.524%, is below the maximum required amount of 75%.

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201258959

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved Exception.

The residual income, $4094, is above the required amount of $3250. The reserves, 8.43 months, are in excess of program requirements of 3 months. The loan to value, 69.524%, is below the maximum required amount of 75%.

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201258959

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.45350% or Final Disclosure APR of 8.50700% is in excess of allowable threshold of APOR 3.58% + 1.5%, or 5.08000%.  Non-Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

Reviewer Comment (2017-01-26): All guidelines violations have been addressed by lender.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258959

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-01-26): All guidelines violations have been addressed by lender.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258959

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-26): All guidelines violations have been addressed by lender.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201258959

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI over Guideline max of 50% with Lender approval.

Reviewer Comment (2017-01-26): All guidelines violations have been addressed by lender.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258959

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.45350% or Final Disclosure APR of 8.50700% is in excess of allowable threshold of APOR 3.58% + 1.5%, or 5.08000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201258960

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

59 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-27): Client elects to waive.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201258960

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.35590% or Final Disclosure APR of 8.37700% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201258960

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 8.35590% or Final Disclosure APR of 8.37700% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201258960

Compliance

Compliance

State Compliance

(State High Cost) Maryland Covered Loan (Points and Fees)

Maryland Predatory Lending Law: Points and Fees on subject loan of 4.75290% is in excess of the allowable maximum of  4.00000% of the Total Loan Amount. Points and Fees total $15,595.00 on a Total Loan Amount of $328,115.60 vs. an allowable total of $13,124.62 (an overage of $2,470.38 or .75290%).  Compliant High Cost Loan.

Verified fees were input correctly.

Reviewer Comment (2017-02-07): Received post close CD reflecting seller paid discount point.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258960

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller at Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

CD reflects $ calculates to be $

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258960

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $2.25, calculates to be $1071.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258960

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $25,856.25.  Borrower's CD reflects $241,705.40, however calculates to be $241,925.40.  Data is still not accurate on subsequent CD

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258960

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,233.75 exceeds tolerance of $150.00 plus 10% or $165.00.  Insufficient or no cure was provided to the borrower. (0)

$1068.75 violation.  $1,113.75 is paid by the seller, however it is customary in the state of MD for the buyer to pay recording fees.  Note:   Borrower's CD the fee is reflected as recording.  Seller's CD the fee is reflected as State Recordation Tax to [REDACTED].

Reviewer Comment (2017-02-03): Received evidence that fee is a Recordation Tax, not a recording fee, and tax is customarily paid be buyer.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201258960

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Cure provided on Closing Disclosure

Reviewer Comment (2017-01-26): Final CD reflects $2.25 Lender Credit for tolerance cure.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201258960

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201258960

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201258960

Credit

Credit

Credit Eligibility

There are red flags on the fraud report that have not been addressed

Fraud report risk score not acceptable.

Reviewer Comment (2017-02-03): Received attestation that lender is satisfied with the resolutions to red flags.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258961

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

18 months reserves LTV is 80% - max for this product 90% 72 months of satisfactory mortgage history on departing residence

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201258961

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.07640% or Final Disclosure APR of 6.07600% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201258961

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller at Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

CD reflects $, calculates to be $.  Data is still not accurate on subsequent CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258961

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - Before Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller Before Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

CD reflects $8,846.92, calculates to be $50,936.92.   Data is still not accurate on subsequent CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258961

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

CD reflects $2352, calculates to be $2402.40.  ($171.60 x 14).  Data was corrected on subsequent CD, however no evidence in file of Letter of Explanation, required to cure violation.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258961

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $105,094.87.  Borrower's CD reflects $669,944.45 at close + $50,936.92 before close.  Data is still ntot accurate on subsequent CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258961

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Caliber approved exception

18 months reserves LTV is 80% - max for this product 90% 72 months of satisfactory mortgage history on departing residence

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201258961

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.07640% or Final Disclosure APR of 6.07600% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Non-Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

Reviewer Comment (2017-01-26): All guidelines violations have been addressed by lender.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258961

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-01-26): All guidelines violations have been addressed by lender.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258961

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-26): All guidelines violations have been addressed by lender.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201258961

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI over 50% Guideline Max, Lender approved.

Reviewer Comment (2017-01-26): All guidelines violations have been addressed by lender.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258961

Compliance

Compliance

Federal Compliance

ARM Disclosure Status

Unable to determine if loan file contains ARM Disclosure due to missing information.

Disclosure not dated.

Reviewer Comment (2017-02-03): Received evidence that borrower received disclosure within timing requirements

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258961

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.07640% or Final Disclosure APR of 6.07600% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201258962

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this Full documentation loan has a disposable income of $1,529.86. Guidelines required $600.00. Guideline variance approved by lender at time of origination. Guidelines maximum of 80%. Actual LTV is 75%. Guidelines require 3 months reserves.  Actual reserves of 9.51 months

Reviewer Comment (2017-01-27): Client elects to waive.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201258962

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller closing disclosure reflects seller paid fees of $23,472.55. Final Closing Disclosure reflect seller paid fees of $4,147.55. A Post closing disclosure dated [MM/DD/YYYY] reflects seller paid fees of $23,472.55.

Reviewer Comment (2017-01-27): Exception cured on [MM/DD/YYYY] with post closing CD.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201258962

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Guideline maximum of 50%. Lender approved exception for 53%.

Borrower on this Full documentation loan has a disposable income of $1,529.86. Guidelines required $600.00. Guideline variance approved by lender at time of origination. Guidelines maximum of 80%. Actual LTV is 75%. Guidelines require 3 months reserves.  Actual reserves of 9.51 months

Reviewer Comment (2017-01-27): Client elects to waive.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201258962

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.20640% or Final Disclosure APR of 8.21100% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Non-Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

Reviewer Comment (2017-01-27): All guidelines violations have been addressed by lender.

01/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258962

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-01-27): All guidelines violations have been addressed by lender.

01/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258962

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-01-27): All guidelines violations have been addressed by lender.

01/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201258962

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Guideline maximum DTI of 50%. Lender approved exception for 53%.

Reviewer Comment (2017-01-27): All guidelines violations have been addressed by lender.

01/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201258962

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.20640% or Final Disclosure APR of 8.21100% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201258963

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

31% DTI on this full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2017-01-26): Client elects to waive.

01/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201258963

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.38180% or Final Disclosure APR of 6.38200% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201258963

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller fees reflected on the Final Closing Disclosure are $8,000. The Seller Disclosure reflects Seller paid fees of $17,374.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201258963

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-01-26): Cured at closing.

01/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201258964

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.27380% or Final Disclosure APR of 6.27400% is in excess of allowable threshold of APOR 3.32% + 2.5%, or 5.82000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

D

B

201258964

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201258964

Compliance

Compliance

Federal Compliance

TRID - the file contains an illegible TRID disclosure. Testing is incomplete

Missing pages 3 thru 5.  Although CD was issued [MM/DD/YYYY], same as another complete disclosure, this one reflects cash to close of  and the completed CD reflects .  Disclosure is not reflected as an estimate or draft copy.

Reviewer Comment (2017-01-30): Received complete copy of CD.

01/30/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

A

D

A

D

A

D

A

D

A

Higher Priced QM

Higher Priced QM

Yes

D

B

201260095

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

35 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-27): Client elects to waive.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201260095

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.49590% or Final Disclosure APR of 8.49600% is in excess of allowable threshold of APOR 3.32% + 1.5%, or 4.82000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201260095

Compliance

Compliance

State Compliance

DC Mortgage Disclosure Amendment Act of 2007 (Mortgage Disclosure Not Provided Timely)

DC Mortgage Disclosure Amendment Act of 2007:  Mortgage Disclosure not provided to borrower within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201260095

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

CD reflects $1243, calculates to be $1124.04.  ($93.67 x 12)

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260095

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on [MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201260095

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $69.12.  Cure for decreased Lender Credit was not provided.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260095

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-1,450.88  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,520.00. (9300)

Loan Estimate dated 12/21 reflects $1520 Lender Credit (loan was locked) and Final CD reflects $1450.88 Lender Credit.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.

Reviewer Comment (2017-02-14): Trail of VCC shows lender credit adjusted accurately.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201260095

Credit

Credit

Misc

Credit Exception:

Please provide evidence of the disposition for property located at , which is listed on 2015 and 2014 Sch E.  DTI subject to change.

Reviewer Comment (2017-02-03): Received evidence that property no longer in borrower's possession.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201260096

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.30580% or Final Disclosure APR of 6.30600% is in excess of allowable threshold of APOR 3.55% + 1.5%, or 5.05000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201260096

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201260096

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

CD reflects $614.55, calculates to be $694.65.  ($46.31 x 15)   Note:  data is corrected on subsequent CD reflecting $40.97x15=$614.55, however file is missing Letter of Explanation to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201260096

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income required is $1,950, actual is $4,123.35. Excess is $2,173.35. Excess funds for reserves $5,081.71. DTI ratio is 34.026%/38.316%. LTV is 90%.

Reviewer Comment (2017-01-27): Client elects to waive.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201260096

Credit

Credit

Misc

Credit Exception:

Lender Approved Exception:  Borrower qualifies for better program based on the foreclosure deed out of the borrowers ownership executed and filed , signed  and recorded.

Residual income required is $1,950, actual is $4,123.35. Excess is $2,173.35. Excess funds for reserves $5,081.71. DTI ratio is 34.026%/38.316%. LTV is 90%.

Reviewer Comment (2017-01-27): Client elects to waive.

01/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201260097

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

22% DTI on this full documentation loan < 50% guideline max - 28% below program guideline maximum

Reviewer Comment (2017-01-30): Client elects to waive.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201260097

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.24360% or Final Disclosure APR of 6.24400% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD fees total $580.38, while closing CD seller's fees total $2446.01.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Closing Protection, Settlement, Courier, E-Recording, Title Insurance, Loan Tie-In, Notary and Endorsement fees reflected in section B, should be in section C.  Provider used is not listed on the SSPL.

Reviewer Comment (2017-02-15): Received corrected CD with fee listed in correct section.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $189.00 exceeds tolerance of $125.00 plus 10% or $137.50.  Insufficient or no cure was provided to the borrower. (0)

$51.50 violation due to increase in recording fees.  Fee listed in Section B but Vendor is not on SSPL.

Reviewer Comment (2017-02-15): Received corrected CD with fee listed in correct section.  No tolerance violation.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $475.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee not disclosed on LE.

Reviewer Comment (2017-01-28): Final CD reflects $504.29 Lender Credit for tolerance cure.

01/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Courier / Express Mail / Messenger Fee.  Fee Amount of $20.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75187)

Fee not disclosed on LE.  Fee listed in Section B but Vendor is not on SSPL.

Reviewer Comment (2017-02-15): Received corrected CD with fee listed in correct section.  No tolerance violation.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $20.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75197)

Fee not disclosed on LE.

Reviewer Comment (2017-01-28): Final CD reflects $504.29 Lender Credit for tolerance cure.

01/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7564)

Fee not disclosed on LE.  Fee listed in Section B but Vendor is not on SSPL.

Reviewer Comment (2017-02-15): Received corrected CD with fee listed in correct section.  No tolerance violation.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Notary Fee.  Fee Amount of $175.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7568)

Fee not disclosed on LE.  Fee listed in Section B but Vendor is not on SSPL.

Reviewer Comment (2017-02-15): Received corrected CD with fee listed in correct section.  No tolerance violation.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $504.29, calculates to be $740.  Fee listed in Section B but Vendor is not on SSPL.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260097

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-02-03): Received evidence that borrower received disclosure within timing requirements

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201260098

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Coverage Amount.  $ Estimated Cost New.  $ Loan amount.

Reviewer Comment (2017-02-09): Received copy of insurer's replacement cost calculator.  Coverage is sufficient.

02/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201260098

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

29 months reserves > 6 months guideline minimum

Reviewer Comment (2017-01-30): Client elects to waive.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201260098

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.17920% or Final Disclosure APR of 8.17900% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201260098

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.17920% or Final Disclosure APR of 8.17900% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201260098

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY]), but transaction consummation (mortgage notary) date was [MM/DD/YYYY]).

Reviewer Comment (2017-02-03): Data correct on subsequent CDs (SFIG).

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201260098

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $37,581.94.  Borrower's CD reflects $36,174.43.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260098

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant:  Missing payee for Home Warranty Fee.  CD indicates TBD.

Reviewer Comment (2017-02-03): Data correct on subsequent CDs (SFIG).

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201260098

Credit

Credit

Misc

Credit Exception:

CDA fee charged but no report supplied.

Reviewer Comment (2017-02-08): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201260099

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller at Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

CD reflects $, calculates to be $.  Lender included $ POC in calculations.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260099

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - Before Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller Before Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $314.  Lender included POC funds in total of Seller paid funds at closuing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260099

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $123,868.50.  Borrower's CD reflects $123,918.50 at closing + $314 before closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201260099

Credit

Credit

Misc

Credit Exception:

Lender Approved Procedural Exception to allow realtor to credit $3,000 towards closing costs.

19 months reserves > 9 months guideline minimum

Reviewer Comment (2017-01-30): Client elects to waive.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201260099

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review report date not provided.

19 months reserves > 9 months guideline minimum

Reviewer Comment (2017-01-30): Client elects to waive.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201260100

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

CD reflects $1,082, calculates to be $1802.04  (157.17 x 12).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201260100

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201260100

Credit

Loan Package Documentation

Closing / Title

Title: Evidence of title is missing

Reviewer Comment (2017-02-03): Received copy of title.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201260100

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.80280% or Final Disclosure APR of 8.80600% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201260100

Compliance

Compliance

State Compliance

South Carolina Home Loan (Acknowledgement of Receipt of Complaint Agency Disclosure Not In File)

South Carolina Home Loan: Borrower did not acknowledge receipt of document specifying the agency designated to receive complaints or inquiries about the origination and making of the loan.

Reviewer Comment (2017-02-03): Received executed copy of disclosure.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201260100

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $107.88, calculates to be $109.88.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201260100

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $1,906.01 exceeds tolerance of $1,796.13.  Sufficient or excess cure was provided to the borrower. (7200)

Fee disclosed as $1,796.13 on CD dated[MM/DD/YYYY] and as $1,906.01 on Final CD.

Reviewer Comment (2017-01-30): Cured at closing.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201260100

Credit

Credit

Misc

Credit Exception:

Fee for CDA collected, but no report provided.

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201260101

Compliance

Compliance

Federal Compliance

QM Employment History

Qualified Mortgage (Dodd-Frank 2014): Employment history requirement not met.

2 year employment history was not provided.  File contains a processor certification that states that the borrower's current employer merged with the prior employment.  An article was provided as proof of the merger.  2014 W2 reflects proof that borrower worked for acquired company.  However, will need actual evidence of 2 year history, either through VOE, paystub prior to 6/14 or 2013 W2 reflecting .  The hardship in obtaining VOE has been noted, so alternative documentation will be considered.

Reviewer Comment (2017-02-08): Received required job history.

02/08/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

No

C

C

201260101

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/[MM/DD/YYYY])

The files contains two copies of the appraisal with the same effective date of .  Report date on  was . The Report date on  was  both after closing.  Signature date after receipt indicates that changes were made to initial appraisal report.  Missing list of changes and LOE on why changes were made after closing.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

No

C

C

201260101

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-08): File switched to Safe Harbor designation. Reviewer Comment (2017-02-08): File is no longer in Non-QM status.  However, designation mismatch still exists as file is QM, not Rebutable Presumption.

02/08/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

Yes

C

C

201260101

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

3

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

C

C

C

C

C

C

C

C

C

Higher Priced QM

Safe Harbor QM

No

C

C

201260101

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

70% LTV < 80% guideline max

Reviewer Comment (2017-01-30): Client elects to waive.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Safe Harbor QM

No

C

C

201260101

Credit

Loan Package Documentation

Application / Processing

Missing Document: AUS not provided

Reviewer Comment (2017-02-06): AU not required due to the loan amount exceeding the loan limit.  Per guidelines DU is not required.

02/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

No

C

C

201260101

Compliance

Compliance

Federal Compliance

Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing

FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Notice of Special Flood Hazard Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

No

C

C

201260101

Credit

Assets

Asset Documentation

Aged document: Asset Account is older than guidelines permit

Financial Institution: / End Date: [MM/DD/YYYY] // Account Type: Checking / Account Number:, Financial Institution:  / End Date: [MM/DD/YYYY] // Account Type: Money Markets / Account Number

Bank Statement > 90 days from Note.

70% LTV < 80% guideline max

Reviewer Comment (2017-02-08): Client elects to waive.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Safe Harbor QM

No

C

C

201260101

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM matches the Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-02-08): File switched to Safe Harbor QM.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

C

201260102

Compliance

Compliance

Federal Compliance

Investment Property Submitted as QM

Qualified Mortgage (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Qualified Mortgage requirements.

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

No

B

B

201260102

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

Reviewer Comment (2017-01-30): Data was corrected on post close CD (SFIG).

01/30/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

N/A

Yes

B

B

201260102

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $78,950.03, while closing CD seller's fees total $57,133.00.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

B

B

201260102

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Fee disclosed as ($650.00) on (LE or CD dated 0[MM/DD/YYYY]), but disclosed as ($750.00) on Final Closing Disclosure.

Reviewer Comment (2017-01-30): Cured at closing.

01/30/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

N/A

Yes

B

B

201260102

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee.  Fee Amount of $650.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75104)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2017-01-30): Cured at closing.

01/30/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

N/A

Yes

B

B

201260103

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-02-03): Designation switched to Safe Harbor.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201260103

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

32.79% DTI on this (Documentation Type) documentation loan <50.00% guideline max - 17.21% below program guideline maximum Borrower has employment stability for 20 years in the[REDACTED] industry. And residual income of $14,6540.27 mo

Reviewer Comment (2017-01-30): Client elects to waive.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Safe Harbor QM

No

C

B

201260103

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201260103

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM matches the Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-02-03): Designation switched to Safe Harbor.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201260230

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

126 months reserves > 3 months guideline minimum

Reviewer Comment (2017-01-30): Client elects to waive.

01/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201260230

Compliance

Compliance

Federal Compliance

Social Security Documentation

Qualified Mortgage (Dodd-Frank 2014): Social Security income documentation insufficient.

Missing awards letter.

Reviewer Comment (2017-02-14): File switched to Non-QM.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201260230

Compliance

Compliance

Federal Compliance

Social Security Documentation

Qualified Mortgage (Dodd-Frank 2014): Social Security income documentation insufficient.

Missing awards letter.

Reviewer Comment (2017-02-14): File switched to Non-QM.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201260230

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

No

C

B

201260230

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.96150% or Final Disclosure APR of 7.97300% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201260230

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-14): File switched to Non-QM.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201260230

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201260230

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower:

For both  borrowers.

126 months reserves > 3 months guideline minimum 40% DTI on this full documentation loan < 50% guideline max - 10% below program guideline maximum

Reviewer Comment (2017-03-30): Client elects to waive.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201260230

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-14): File switched to Non-QM.

02/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264217

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

135 months reserves > 2 months guideline minimum 57.97% LTV < 70.00 guideline

Reviewer Comment (2017-02-01): Client elects to waive.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201264217

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.19750% or Final Disclosure APR of 8.19800% is in excess of allowable threshold of APOR 3.97% + 1.5%, or 5.47000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201264217

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Pest Inspection Fee.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75155)

Reviewer Comment (2017-01-30): Cured with Lender credit at closing

01/30/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201264218

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

26% DTI on this full documentation loan < 50% guideline max - 24% below program guideline maximum

Reviewer Comment (2017-02-01): Client elects to waive.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264218

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264218

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $20,229.75 exceeds tolerance of $19,946.00.  Sufficient or excess cure was provided to the borrower at Closing. (73109)

Reviewer Comment (2017-01-31): Cured with credit at closing

01/31/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201264218

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,098.90 exceeds tolerance of $1,084.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-01-31): Cured with credit at closing

01/31/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201264219

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264219

Credit

Credit

Misc

Credit Exception:

LOE states new purchasers of borrowers departing res are allowing borrowers to rent back property rent free with no deadline to move out.  However this contradicts purchase contract that states borrowers must vacate property by .  Missing formal and executed contract amendment with the move out deadline removed.

Reviewer Comment (2017-02-03): LOE dated after purchase contract will be used as proof of no rental payments.

02/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264220

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

Required residual income is $1,000 and actual is $1,307.93. Required reserves are 9 months and actual are 13 months. Minimal increase in payment from previous payment. 9.2% increase.

Reviewer Comment (2017-02-01): Client elects to waive.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264220

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.57460% or Final Disclosure APR of 7.57500% is in excess of allowable threshold of APOR 3.55% + 1.5%, or 5.05000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-02-01): All guidelines violations have been addressed by lender.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264220

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-02-01): All guidelines violations have been addressed by lender.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264220

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-01): All guidelines violations have been addressed by lender.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201264220

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-01): All guidelines violations have been addressed by lender.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264220

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly amount reflects $121.83, however prepaid homeowner's insurance reflects $1575.25, should be $1461.96.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264220

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on[MM/DD/YYYY] reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section. (Final/[MM/DD/YYYY])

Section B reflects paid to broker/lender; payee must reflect the actual vendor in some manor (FBO, reimbursement to, etc).

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264220

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.57460% or Final Disclosure APR of 7.57500% is in excess of allowable threshold of APOR 3.55% + 1.5%, or 5.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Non QM

Non QM

No

C

B

201264221

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

35% DTI on this documentation loan < 50% guideline max - 15% below program guideline maximum

Reviewer Comment (2017-02-01): Client elects to waive.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201264221

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.50810% or Final Disclosure APR of 7.50800% is in excess of allowable threshold of APOR 4.12% + 1.5%, or 5.62000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201264221

Compliance

Compliance

State Compliance

Minnesota Subprime Threshold Test Fixed Loan

Minnesota Subprime Loan: APR on subject loan of 7.50810% or Final Disclosure APR of 7.50800% is in excess of allowable threshold of USTreasury 2.9700% + 3%, or 5.97000%.  Compliant Subprime Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201264221

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-02-17): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-02-09): Received rebuttal that the 23rd is after the 3rd business day from the 18th.  However:  receipt date the 18th; 3 business days = 19th, 20th, 23rd, available closing date is the 24th. Reviewer Comment (2017-02-07): Per document sent in, received date was the 18th and therefor the violation is accurate.

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264221

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $10,289.96, while closing CD seller's fees total $116,521.33.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201264222

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.68240% or Final Disclosure APR of 6.68200% is in excess of allowable threshold of APOR 3.55% + 1.5%, or 5.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201264222

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-09): Designation switched to Non-QM.

02/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201264222

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Qualification method for QM is Max Rate within the first 5 years.

Reviewer Comment (2017-02-09): Designation switched to Non-QM.

02/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201264222

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $18,407.00, while closing CD seller's fees total $25,403.74.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264222

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Post Close Desk Review Appraisal was not provided.

674 representative FICO score > 620 guideline minimum - 54 points above guideline minimum

Reviewer Comment (2017-02-01): Client elects to waive.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201264222

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-09): Designation switched to Non-QM.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264223

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.76650% or Final Disclosure APR of 6.76700% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.76650% or Final Disclosure APR of 6.76700% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure of ($35.74) was reflected, which is insufficient to cure ($850.74)

Reviewer Comment (2017-02-03): Received attestation that 11/9 disclosure was produced by title and never presented to borrower.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $815.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Rate lock and LEs reflect correct discount amount along with VCC.  However, CD issued 11/9 rebaselines fee to $0.

Reviewer Comment (2017-02-03): Received attestation that 11/9 disclosure was produced by title and never presented to borrower.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $60.74 exceeds tolerance of $25.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-01-31): Cure provided on Final CD. Reviewer Comment (2017-01-31): invalid Reviewer Comment (2017-01-31): Lender provided credit of $35.74 at closing.

01/31/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201264223

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

31% DTI on this full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2017-02-01): Client elects to waive.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing vs Closing Disclosure

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (Interim/[MM/DD/YYYY])

Initial Closing Disclosure provided [MM/DD/YYYY].

Reviewer Comment (2017-02-03): Received attestation that 11/9 disclosure was produced by title and never presented to borrower.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing vs Closing Disclosure

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (Interim/[MM/DD/YYYY])

Initial Closing Disclosure provided [MM/DD/YYYY].

Reviewer Comment (2017-02-03): Received attestation that 11/9 disclosure was produced by title and never presented to borrower.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing vs Closing Disclosure

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (Interim/[MM/DD/YYYY])

Initial Closing Disclosure provided [MM/DD/YYYY].

Reviewer Comment (2017-02-03): Received attestation that 11/9 disclosure was produced by title and never presented to borrower.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing vs Closing Disclosure

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (Interim/[MM/DD/YYYY])

Initial Closing Disclosure provided [MM/DD/YYYY].

Reviewer Comment (2017-02-03): Received attestation that 11/9 disclosure was produced by title and never presented to borrower.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing vs Closing Disclosure

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (Interim/[MM/DD/YYYY])

Initial Closing Disclosure provided [MM/DD/YYYY].

Reviewer Comment (2017-02-03): Received attestation that 11/9 disclosure was produced by title and never presented to borrower.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing vs Closing Disclosure

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (Interim/[MM/DD/YYYY])

Initial Closing Disclosure provided [MM/DD/YYYY].

Reviewer Comment (2017-02-03): Received attestation that 11/9 disclosure was produced by title and never presented to borrower.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264223

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $60.74 exceeds tolerance of $25.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-02-03): Cured at closing.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201264224

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.26570% or Final Disclosure APR of 6.26600% is in excess of allowable threshold of APOR 3.36% + 2.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201264224

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264224

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-08): Designation switched to Non-QM.

02/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201264224

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

QM requires qualification method to use the maximum rate in the first 5 years.

Reviewer Comment (2017-02-08): Designation switched to Non-QM.

02/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201264224

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Post Close Desk Review Appraisal was not provided.

Reviewer Comment (2017-02-03): Exception created in error.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201264224

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-08): Designation switched to Non-QM.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264225

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $59,467.00, while closing CD seller's fees total $60,746.96.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264225

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2017-02-01): Cured at closing.

02/01/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201264225

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2017-02-13): Received copy of insurer's replacement cost estimator.  Coverage is sufficient. Buyer Comment (2017-02-13): Disregard first upload.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264226

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.82090% or Final Disclosure APR of 8.82100% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201264226

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $20,143.00, while closing CD seller's fees total $18,293.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264226

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

66 months reserves > 6 months guideline minimum

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264227

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

CD reflects $786.48, calculates to be $853.44.  ($71.12 x 12)

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264227

Credit

Credit

Misc

Credit Exception:

Lender Approved:  To allow a condotel continue that is not  under a nationally recognized chain.

Current dti/qualifying rations are 18.503%/54.512%. Actual residual income of $5254.71 and required is $2700, a different of $2554.71. Borrowers have an excess of 100 months of reserves and program only requires 3 months reserves. Mortgage payment history reflects 0x30 in the past 38 months and Premier Access only requires a 24 month look back.

Reviewer Comment (2017-02-01): Client elects to waive.

02/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264227

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved DTI Exception on Premier Access at 80% LTV.

Current dti/qualifying rations are 18.503%/54.512%. Actual residual income of $5254.71 and required is $2700, a different of $2554.71. Borrowers have an excess of 100 months of reserves and program only requires 3 months reserves. Mortgage payment history reflects 0x30 in the past 38 months and Premier Access only requires a 24 month look back.

Reviewer Comment (2017-02-01): Client elects to waive.

02/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264227

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Current dti/qualifying rations are 18.503%/54.512%. Actual residual income of $5254.71 and required is $2700, a different of $2554.71. Borrowers have an excess of 100 months of reserves and program only requires 3 months reserves. Mortgage payment history reflects 0x30 in the past 38 months and Premier Access only requires a 24 month look back.

Reviewer Comment (2017-02-15): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/15/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264227

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-01): All guidelines violations have been addressed by lender.

02/01/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201264227

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-01): All guidelines violations have been addressed by lender.

02/01/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264975

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

18 months reserves > 3 months guideline minimum - borrowers have verified reserves of $74,039.50. 33.768% DTI on this Full documentation loan < 50% guideline max - 16.232% below program guideline maximum 80% LTV < maximum 90% LTV.

Reviewer Comment (2017-02-02): Client elects to waive.

02/02/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264975

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264975

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $10,778.59 exceeds tolerance of $9,949.00.  Sufficient or excess cure was provided to the borrower at Closing. (7200)

Reviewer Comment (2017-02-02): Cured at closing.

02/02/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201264975

Credit

Credit

Misc

Credit Exception:

Lender Approved Exception for using gift funds on the purchase of a 2nd home.

18 months reserves > 3 months guideline minimum - borrowers have verified reserves of $74,039.50. 33.768% DTI on this Full documentation loan < 50% guideline max - 16.232% below program guideline maximum 80% LTV < maximum 90% LTV.

Reviewer Comment (2017-02-02): Client elects to waive.

02/02/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264976

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

38% DTI on this full documentation loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2017-02-02): Client elects to waive.

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201264976

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.75450% or Final Disclosure APR of 7.75500% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201264976

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $19,526.50, while closing CD seller's fees total $22,166.42.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201264976

Compliance

Compliance

Federal Compliance

TRID non-compliant:  There is a partially completed TRID disclosure in file, which is insufficient to complete testing.

Page 485, There is no issue date or interest rate.

Reviewer Comment (2017-02-06): Seller provided attestation that the CD in question was not provided to the borrower but was for the title company reference only.

02/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201264977

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.44660% or Final Disclosure APR of 8.44700% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

A

A

201264978

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.52970% or Final Disclosure APR of 6.53000% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

A

A

201264978

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Cure provided on Closing Disclosure

Reviewer Comment (2017-02-02): Cured at closing.

02/02/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

A

A

201264979

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.90610% or Final Disclosure APR of 6.90600% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201264979

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $59,270.  Borrower's CD reflects $65,270.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264979

Credit

Credit

Misc

Credit Exception:

Lender approved exception to allow for use of foreign assets for reserves.

Borrower on this full documentation loan has a disposable income of $21,149.12 exceeds required $6200 by $14949.12. 28.70% DTI on this full documentation loan < 50% guideline max - at 28.70% Both borrowers have additional income that was not used for qualifying.

Reviewer Comment (2017-02-02): Client elects to waive.

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264979

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved.

Borrower on this full documentation loan has a disposable income of $21,149.12 exceeds required $6200 by $14949.12. 28.70% DTI on this full documentation loan < 50% guideline max - at 28.70% Both borrowers have additional income that was not used for qualifying.

Reviewer Comment (2017-02-02): Client elects to waive.

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264980

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

27.6% DTI on this Full documentation loan < 50% guideline max Borrower on this Full documentation loan has a disposable income of $11,666.32

Reviewer Comment (2017-02-15): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264980

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for $150 Collateral Desk Review was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264980

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-03-03): LE with accurate loan terms has evidence that it was received within timing requirements.  This is acceptable. Reviewer Comment (2017-02-21): Exception should have been explained better.  There are 2 LEs issued on 1/19.  The LE with the 6.375% is within timing requirements.  The LE with the 6.50% does not have proof of receipt.

03/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264980

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264980

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee not disclosed on LE dated 1[MM/DD/YYYY].

Reviewer Comment (2017-02-15): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201264980

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.58810% or Final Disclosure APR of 6.58600% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201264980

Credit

Credit

Misc

Credit Exception:

Lender Approved a Procedural Exception for agent credits of $1,000.

27.6% DTI on this Full documentation loan < 50% guideline max Borrower on this Full documentation loan has a disposable income of $11,666.32

Reviewer Comment (2017-02-02): Client elects to waive.

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264982

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

86 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264982

Compliance

Loan Package Documentation

Closing / Title

(Missing Doc) PUD Rider was not provided.

Reviewer Comment (2017-03-09): Received copy of executed PUD rider. Reviewer Comment (2017-02-09): Legal description on appraisal states property is a PUD. Buyer Comment (2017-02-08): Property is not a PUD

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264982

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.49580% or Final Disclosure APR of 8.52100% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201264982

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-07): File switched to Non-QM

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201264982

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Reviewer Comment (2017-02-07): File switched to Non-QM

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201264982

Compliance

Compliance

Federal Compliance

QM Points and Fees

Qualified Mortgage (Dodd Frank 2014): Points and Fees on subject loan of 4.61038% is in excess of the allowable maximum of  3.00000% of the Federal Total Loan Amount. Points and Fees total $17,408.29 on a Federal Total Loan Amount of $377,589.04 vs. an allowable total of $11,327.67 (an overage of $6,080.62 or 1.61038%).

Reviewer Comment (2017-02-07): File switched to Non-QM

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

If a creditor or assignee determines after consummation that the total points and fees exceeds the 3% limit, but the loan meets the other requirements to be a QM, the excess amount can be refunded with the following conditions: 1) The refund is made within 210 days of consummation; 2) The consumer has not instituted any actions against the creditor or provided written notice that the loan's fees exceeded the legal limit; 3) The loan is not 60 days delinquent; 4) The creditor or assignee (depending who is curing) has policies in place to identify and cure excessive fees collected from the consumer (the creditor or assignee can only take advantage of this cure provision if they maintain policies and procedures for post-consummation review of points and fees and for providing the cure payments). The lender will also be required to provide a copy of the refund check and proof of delivery.

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201264982

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a negative fee amount. (Final/[MM/DD/YYYY])

Disclosure reflects a negative fee for (Title - Owner's Title Insurance) in Section (H).  This is TRID non-compliant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264982

Compliance

Compliance

Federal Compliance

TRID non-compliant:  There is a partially completed TRID disclosure in file, which is insufficient to complete testing.

Reviewer Comment (2017-02-07): Received attestation that disclosure was produced by title and never presented to borrower.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201264983

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201264984

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.50730% or Final Disclosure APR of 8.51800% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201264984

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $12,920.61.  Borrower's CD reflects $160,847.58.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201264984

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

30% DTI on this full documentation loan < 50% guideline max - 20% below program guideline maximum

Reviewer Comment (2017-02-03): Unsettled Loan

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201264984

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $85.50 exceeds tolerance of $25.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-02-03): Cured at close.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201264985

Credit

Loan Package Documentation

Closing / Title

Missing Document: Condo Rider was not provided.

Reviewer Comment (2017-03-16): Received copy of executed Condo Rider.

03/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

No

C

B

201264985

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

24 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-02): Client elects to waive.

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Safe Harbor QM

No

C

B

201264985

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-02-22): Designation switched to Safe Harbor QM.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201264985

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for $183.69 decreased Lender Credit was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201264985

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-2,441.31  is less than amount of binding Lender Credit previously disclosed in the amount of $-2,625.00. (9300)

Loan Estimate dated [MM/DD/YYYY] reflects $2625 Lender Credit (loan was locked) and Final CD reflects $5441.31 Lender Credit.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.

Reviewer Comment (2017-02-09): Credit listed on page 3 moved to correct section on page 2 and total amount of credit is amount reflected on [MM/DD/YYYY] LE.

02/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201264985

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $67,519.95.  Borrower's CD reflects $692,420.72.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201264985

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $72.98 exceeds tolerance of $50.00.  Insufficent or no cure was provided to the borrower. (7520)

The Final Closing Disclosure reflects a cure of $22.98 for costs above the legal limit.

Reviewer Comment (2017-02-01): Final CD reflects $22.98 Lender Credit for tolerance cure.

02/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201264985

Credit

Credit

Misc

Credit Exception:

Please verify the amount used for monthly tax escrows.  Amount appears to be based on appraisal which is not an official tax document.  DTI subject to change.

Reviewer Comment (2017-02-16): Received documentation and confirmation that taxes used are sufficient for escrow account.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

No

C

B

201264985

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM matches the Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-02-22): Designation switched to Safe Harbor QM.

02/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201264986

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

53 months reserves > 9 months guideline minimum

Reviewer Comment (2017-02-07): Client elects to waive.

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201264986

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.53090% or Final Disclosure APR of 6.52900% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201264986

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.53090% or Final Disclosure APR of 6.52900% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201264986

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75103)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2017-02-02): Lender gave $150 credit at closing.

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201264986

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $16,117.74, while closing CD seller's fees total $222,227.99.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201264987

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

713 representative FICO score > 620 guideline minimum - 93 points above guideline minimum

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201264987

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-02): File contains evidence that a more recent disclosure that reflects accurate terms of loan has been received within timing requirements.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264987

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

Evidence of earlier borrower receipt was not found in file for CD issued 1/18.

Reviewer Comment (2017-03-02): File contains evidence that a more recent disclosure that reflects accurate terms of loan has been received within timing requirements.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201264987

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $61,099.47, while closing CD seller's fees total $1,020,186.85.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201264987

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $91.50 exceeds tolerance of $48.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Fee disclosed as ($48.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($91.50) on Final Closing Disclosure.

Reviewer Comment (2017-02-03): Cured at closing.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201272393

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

74 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201272393

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201272394

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

48 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

No

C

B

201272394

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.21550% or Final Disclosure APR of 8.34100% is in excess of allowable threshold of APOR 3.43% + 2.5%, or 5.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201272394

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Final Closing Disclosure Summaries cash from borrower amount is $108,905.57. Final Cash to close in Calculating cash to close section reflects $109,905.57.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201272394

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TIP of 170.169% but calculated TIP is 167.788%), which is outside of .003% tolerance.  Unable to determine what lender used for index.  Review used 1.64456%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201272394

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

CD dated [MM/DD/YYYY]. No evidence that CD was received at least three days prior to closing.

Reviewer Comment (2017-02-16): Received attestation that disclosure was produced by title and never presented to borrower.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201272394

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller closing disclosure reflects seller paid fees of $26,146.88. Final Closing Disclosure reflects seller paid fees of $2,050.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201272394

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Coverage shortage of $19745.

Reviewer Comment (2017-02-10): Received copy of insurer's replacement cost estimator.  Coverage is sufficient.

02/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

No

C

B

201272394

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-21): Received copy of VCC reflecting no violation.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

A

A

A

A

A

Non QM

Higher Priced QM

Yes

C

B

201272394

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,904.30 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Reviewer Comment (2017-02-21): Received copy of VCC reflecting no violation.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

A

A

A

A

A

Non QM

Higher Priced QM

Yes

C

B

201272394

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-27): Designation switched to Rebuttable Presumption.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201272395

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender Approved Loan Exception in file.

Borrower has $1,899 in residual income > required $1,400 41% DTI on this full documentation loan < 50% guideline max

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201272395

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.48180% or Final Disclosure APR of 8.48600% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201272395

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

(Initial LE) disclosure(s) was issued on the "With Seller" form, and (All other) disclosure(s) was issued on the "Without Seller" form.

Reviewer Comment (2017-02-02): Data was corrected on subsequent disclosure (SFIG).

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201272395

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly amount reflects $84.67, however prepaid homeowner's insurance reflects $25.00, should be $1016.04.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201272395

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $85.60 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Fee disclosed as ($50.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($85.60) on Final Closing Disclosure.

Reviewer Comment (2017-02-03): Cured at closing.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201272395

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as ($90.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($92.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-03): Cured at closing.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201272396

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Additional income of housing allowance has not been used to qualify, compensating factor only. 74.465% LTV < 80% guideline max Borrower on this full documentation loan has a disposable income of $9,630.10.

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201272396

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Lender exception has been approved for DTI at 52.9%.

Reviewer Comment (2017-02-03): All guideline violations have been addressed by lender.

02/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201272396

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Lender exception has been approved for DTI at 52.9%.

Reviewer Comment (2017-02-03): All guideline violations have been addressed by lender.

02/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201272396

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure  [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $31,128.50, while closing CD seller's fees total $-0-.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201272396

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

Additional income of housing allowance has not been used to qualify, compensating factor only. 74.465% LTV < 80% guideline max Borrower on this full documentation loan has a disposable income of $9,630.10.

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201272397

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201272397

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $650.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/16/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201272397

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Reviewer Comment (2017-02-09): Received VCC allowing for addition of fee.

02/09/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201272397

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-02-07): Received evidence that document provided within timing requirements when loan moved from fixed to ARM.

02/07/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201272397

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201272397

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-02-07): Received evidence that borrower received disclosure within timing requirements.

02/07/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201272398

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

754 representative FICO score > 660 guideline minimum - 94 points above guideline minimum

Reviewer Comment (2017-02-21): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201272398

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.74580% or Final Disclosure APR of 5.74800% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201272398

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.74580% or Final Disclosure APR of 5.74800% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201272399

Credit

Credit

Misc

Credit Exception:

Lender Approve Exception to permit use of rental income for subject property on purchase transaction.

Guideline variance approved by lender at time of origination. Compensating factors include: Residual Income required- $2,650 vs actual of $7,500. Cash reserves required $29,800 vs $40,000. FICO required 620 vs actual 725. Borrower has residual income of $7500 > required of $2650 Borrowers have verified reserves of $40,000 > required of $29,710

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

No

C

B

201272399

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

C

B

201272399

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $600.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing. (75103)

Reviewer Comment (2017-02-03): Lender credit provided at closing

02/03/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

N/A

Yes

C

B

201272400

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

20% DTI on this full documentation loan < 50% guideline max - 30% below program guideline maximum

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201272400

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.69730% or Final Disclosure APR of 7.74400% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201272401

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

53 months reserves > 6 months guideline minimum

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201272401

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.95510% or Final Disclosure APR of 7.04100% is in excess of allowable threshold of APOR 3.39% + 2.5%, or 5.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201272401

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Closing Disclosure Total Interest Percentage (136.83000) > (Math Closing Disclosure Total Interest Percentage (134.60200) + 0.003).  Unable to determine what index was used.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201272402

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

36 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-03): Client elects to waive.

02/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201272402

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.91080% or Final Disclosure APR of 7.91100% is in excess of allowable threshold of APOR 4.17% + 2.5%, or 6.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201272403

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.72210% or Final Disclosure APR of 6.72300% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

The loan is designated as higher priced.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201272403

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $23,035.95, while closing CD seller's fees total $291,448.02.  Combined CD included amount required to payoff existing mortgage.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201272403

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Municipal Lien Certificate Fee (MLC).  Fee Amount of $10.00 exceeds tolerance of $5.00.  Sufficient or excess cure was provided to the borrower at Closing. (75214)

Reviewer Comment (2017-02-03): Cured at closing.

02/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

B

B

201273246

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.02650% or Final Disclosure APR of 8.06900% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201273246

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

B

B

201273246

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $29,745.  Borrower's CD reflects $24,862.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201273246

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-06): Lender provided $800 credit to borrower at closing.

02/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

B

B

201273247

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Change of Circumstance located in file page  , but no corresponding CD located in the file

Reviewer Comment (2017-02-10): Lender attests that CoC was begun but never completed and no new disclosure was ever produced.

02/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

A

201273248

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

38% DTI on this full documentation loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Safe Harbor QM

No

C

B

201273248

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Safe Harbor QM.

Loan designation per Bid Tape is Safe Harbor.

Reviewer Comment (2017-02-09): Designation switched to Safe Harbor QM.

02/09/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201273248

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Reviewer Comment (2017-02-24): Received evidence that POC amounts were paid prior to most recent asset statements.

02/24/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

No

C

B

201273248

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM matches the Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-02-09): Designation switched to Safe Harbor QM.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201273249

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual Income of $1160.62 LTV of 64%

Reviewer Comment (2017-02-07): Client elects to waive.

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

C

201273249

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.75940% or Final Disclosure APR of 8.75900% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

C

201273249

Compliance

Compliance

State Compliance

Connecticut HB5577 NP Threshold Test Fixed Loans

Connecticut Non-Prime Home Loan: APR on subject loan of 8.75940% or Final Disclosure APR of 8.75900% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

C

201273249

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Unable to determine source of prepaid figure.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

C

201273249

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

C

201273249

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-02-08): Received evidence that borrower received disclosure within timing requirements.

02/08/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

C

201273249

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-80.00. (9300)

Reviewer Comment (2017-02-16): Received VCC regarding rate lock extension and elimination of Lender Credit.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

C

201273249

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-02-08): The issue isn't the receipt of the 12/13 LE, but rather the day it was sent.  Per 1003, app date is 12/7 so the 12/13 is outside of the 3 day window to get disclosures to the borrower.

3

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

C

C

C

C

C

C

C

C

C

Non QM

Non QM

No

C

C

201273249

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-02-08): Received evidence that borrower received disclosure within timing requirements.

02/08/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

C

201273249

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

Settlement Service Providers List Disclosure Provided Date ([MM/DD/YYYY]) > Lesser Of Creditor Originator Plus 3 ([MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

C

201273249

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $33.45 exceeds tolerance of $30.00.  Insufficent or no cure was provided to the borrower. (7520)

Cure provided on Closing Disclosure

Reviewer Comment (2017-02-06): Cured on closing Cd with lender credit

02/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

C

201273249

Credit

Credit

Misc

Credit Exception:

Lender Approved Exception to allow gift funds for reserves

Residual Income of $1160.62 LTV of 64%

Reviewer Comment (2017-02-06): Client elects to waive.

02/06/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

C

201273250

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.87520% or Final Disclosure APR of 6.92800% is in excess of allowable threshold of APOR 3.51% + 2.5%, or 6.01000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.625 and verified to lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201273250

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Recording Service Fee.  Fee Amount of $346.00 exceeds tolerance of $345.00.  Sufficient or excess cure was provided to the borrower at Closing. (8325)

Reviewer Comment (2017-02-06): This was cured at settlement.

02/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201273250

Compliance

Compliance

Federal Compliance

ARM Disclosure Status

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.

Reviewer Comment (2017-02-21): Received evidence that borrower received disclosure within timing requirements.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201273250

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

686 > required 680

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201273250

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Reviewer Comment (2017-03-02): Lender attests that all red flags have been sufficiently addressed. Reviewer Comment (2017-02-21): Received fraud report but borrower is in Critical Risk category.  Red Flags need to be addressed.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201273250

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Lender's Title Insurance.  Fee Amount of $3,277.00 exceeds tolerance of $3,225.00.  Sufficient or excess cure was provided to the borrower at Closing. (7729)

Reviewer Comment (2017-02-06): This was cured at settlement

02/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201273251

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

39% DTI on this full documentation loan < 50% guideline max - 11% below program guideline maximum

Reviewer Comment (2017-02-07): Client elects to waive.

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201273251

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $48,733.  Borrower's CD reflects $49,336.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201273252

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Exception in the file for the FICO

The residual income, $11,100, is above the required amount of 2750. The reserves, 20 months, are in excess of program requirements of 9 months. Borrower has 17 months of mortgage history and only 12 is required.

Reviewer Comment (2017-02-07): Client elects to waive.

02/07/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201273252

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Amount Financed

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Amount Financed that was not within tolerance of the actual amount financed for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-06): This is cured on the [MM/DD/YYYY] post closing CD.

02/06/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201273252

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-06): This is cured on the [MM/DD/YYYY] post closing CD.

02/06/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201273252

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-06): This is cured on the [MM/DD/YYYY] post closing CD.

02/06/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201273252

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Total of Payments that does not match the actual total of payments for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-06): This is cured on the [MM/DD/YYYY] post closing CD.

02/06/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201273252

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for Estoppel Fee of $50.00 was not provided.

Reviewer Comment (2017-02-23): Received evidence that the estoppel fee is a seller paid fee.

02/23/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Non QM

Yes

C

B

201273252

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Title Estoppel Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7543)

Fee was not disclosed on Loan Estimate. Fee was paid by seller and this fee is not typically paid by seller's in the state of FL.

Reviewer Comment (2017-02-23): Received evidence that the estoppel fee is a seller paid fee.

02/23/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201273252

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-16): Designation switched to Non-QM

02/16/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201273252

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

QM qualification requires the use of the maximum rate in the first 5 years method.

Reviewer Comment (2017-02-16): Designation switched to Non-QM

02/16/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201273252

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-16): Designation switched to Non-QM

02/16/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201273253

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Residual income of $12,105.07 is above the minimum required amount of $8,600 for an excess of $3,505.07. LTV of 80% is below the program maximum of 90%. Income not being used to qualify is coming from K-1 Guaranteed Payments from [REDACTED], in the amount of $2,011 per month averaged over the past 2 years.

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201273253

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Residual income of $12,105.07 is above the minimum required amount of $8,600 for an excess of $3,505.07. LTV of 80% is below the program maximum of 90%. Income not being used to qualify is coming from K-1 Guaranteed Payments from [REDACTED], in the amount of $2,011 per month averaged over the past 2 years.

Reviewer Comment (2017-02-07): Client elects to waive.

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201273253

Credit

Assets

Asset Documentation

Assets Error: Usability  was not provided

Use of Business Assets without obtaining letter from CPA stating use will not negatively affect business.

Residual income of $12,105.07 is above the minimum required amount of $8,600 for an excess of $3,505.07. LTV of 80% is below the program maximum of 90%. Income not being used to qualify is coming from K-1 Guaranteed Payments from [REDACTED] in the amount of $2,011 per month averaged over the past 2 years.

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201273253

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-07): All guideline violations have been addressed by lender.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201273253

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-07): All guideline violations have been addressed by lender.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201273253

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201273254

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

97 months reserves > 9 months guideline minimum

Reviewer Comment (2017-02-08): Client elects to waive.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201273254

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.44080% or Final Disclosure APR of 6.44500% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201273254

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-02-14): Received evidence that borrower received disclosure within timing requirements.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201273254

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

CD reflects not assumable.  Note reflects assumable after fixed rate period.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201273254

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $24,839.50.  Borrower's CD reflects $25,173.75.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201273254

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-08): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201273254

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $4,768.05 exceeds tolerance of $1,975.00.  Sufficient or excess cure was provided to the borrower. (8304)

Reviewer Comment (2017-02-08): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201281559

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $575.  Cure for $425 Discount and $150 Collateral Desktop Analysis was not provided.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201281559

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $2,499.  Borrower's CD reflects $312,732.19.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201281559

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee not disclosed on LE dated 1[MM/DD/YYYY].

Reviewer Comment (2017-02-20): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/20/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201281559

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

157 months reserves > 9 months guideline minimum

Reviewer Comment (2017-02-20): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/20/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201281559

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Closing Protection, Settlement, Courier, Doc Prep, Lender's Title Insurance, Recording Service and Endorsement fees reflected in section C, should be in section B.  Provider used is listed on SSPL.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201281560

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Borrower has job stability for 29 years as an [REDACTED].

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201281560

Credit

Loan Package Documentation

Closing / Title

Missing Lien(s) negatively impacting title

IRS Tax Lien in the amount of shows as outstanding on Title Commitment.  Guidelines state liens/judgments in excess of $25,000 must be brought current.  No evidence in images.  Title Defect.

Reviewer Comment (2017-02-13): Received copy of final title policy that no longer reflects a tax lien.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201281560

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.88820% or Final Disclosure APR of 6.88800% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

Reviewed CD in the file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201281560

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Reviewed CD in the file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201281561

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved the exception

716 representative FICO score > 660 guideline minimum - 56 points above guideline minimum Guideline variance approved by lender at time of origination.  Borrower has 3.92 months of reserves which is > than the 3 months required per guidelines

Reviewer Comment (2017-02-07): Client elects to waive.

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201281561

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

716 representative FICO score > 660 guideline minimum - 56 points above guideline minimum Guideline variance approved by lender at time of origination.  Borrower has 3.92 months of reserves which is > than the 3 months required per guidelines

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201281561

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-07): All guideline violations have been addressed by lender.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201281561

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewed CD

Reviewer Comment (2017-02-07): All guideline violations have been addressed by lender.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201281561

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewed CD

Reviewer Comment (2017-02-07): OK on brokered loans.

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201281562

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.17280% or Final Disclosure APR of 9.17300% is in excess of allowable threshold of APOR 4.22% + 1.5%, or 5.72000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

A

A

201281563

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower's mortgage payment decreased by $3,443 per month Required of $7,550, actual $8,222.35, excess of $672.35 per month.

Reviewer Comment (2017-02-07): client elects to waive.

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201281563

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-07): All guideline violations have been addressed by lender.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201281563

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

The Final Closing Disclosure reflects Homeowner's Premium paid for 12 months at $1,283.76. Per Hazard Insurance policy, the current annual premium is $1,924.09 and the previous annual premium was $1,283.76.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201281563

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception in file.

Borrower's mortgage payment decreased by $3,443 per month Required of $7,550, actual $8,222.35, excess of $672.35 per month.

Reviewer Comment (2017-02-07): client elects to waive.

02/07/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201281563

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-07): All guideline violations have been addressed by lender.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201281563

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.12180% or Final Disclosure APR of 6.04600% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-02-07): All guideline violations have been addressed by lender.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201281563

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-02-07): All guideline violations have been addressed by lender.

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201281563

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

Used index of 1.7007% per documentation in file.  Does not appear this is the correct index.

Reviewer Comment (2017-02-16): Correct index entered and no violations resulted.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201281563

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payoffs and Payments Total

TILA-RESPA Integrated Disclosure - Payoffs and Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Payoffs and Payments that did not match the sum of payoff amounts. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201281563

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-16): Correct index entered and no violations resulted.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201281563

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total of Payments that does not match the actual total of payments for the loan. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-16): Correct index entered and no violations resulted.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201281563

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.12180% or Final Disclosure APR of 6.04600% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-02-16): Correct index entered and no violations resulted.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Non QM

Non QM

No

C

B

201281564

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.22820% or Final Disclosure APR of 6.22800% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201281564

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.22820% or Final Disclosure APR of 6.22800% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

B

B

201281564

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-07): Final Closing Disclosure dated [MM/DD/YYYY] reflects a closing date of[MM/DD/YYYY] and disbursement date of [MM/DD/YYYY].  CD was signed by Borrowers on[MM/DD/YYYY].

02/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

B

B

201281564

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID Non-Compliant: Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $76, 545.50 while Borrower closing CD reflects sellers fees of $73, 642.80

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201281565

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-02-10): Received copy of CDA.

02/10/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201281565

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Reviewer Comment (2017-02-15): Not required on Foreign Nationals.

02/15/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201281565

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Esign Consent Agreement Timing

ESIGN Act - Closing Disclosure provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Interim/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201281565

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201281565

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $278.00 exceeds tolerance of $236.00 plus 10% or $259.60.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-02-08): Cured at closing.

02/08/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201281565

Credit

Loan Package Documentation

Closing / Title

Missing Document: Rider - ARM not provided

Reviewer Comment (2017-02-13): Received a copy of ARM Rider.

02/13/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201281565

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

Foreign Assets can only be used for reserves.

Reviewer Comment (2017-02-16): Received evidence of EMD.  All asset requirements have been met.

02/16/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201288663

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

41 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201288663

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.04940% or Final Disclosure APR of 7.04900% is in excess of allowable threshold of APOR 3.98% + 1.5%, or 5.48000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201288663

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201288663

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for decrease in Lender Credit of $2046 was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201288663

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-2,046.00. (9300)

LE dated [MM/DD/YYYY] reflects $2046 Lender Credit (loan was locked) and Final reflects $0.00 Lender Credit.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.

Reviewer Comment (2017-02-13): Received VCC for reduction of lender credit.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201288663

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-02-08): Final CD reflect $2.00 Lender Credit for tolerance cure.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201288664

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for $23.50 recording fee was not provided.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201288664

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $23,616.  Borrower's CD reflects $240,797.29.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201288664

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $95.00 exceeds tolerance of $65.00 plus 10% or $71.50.  Insufficient or no cure was provided to the borrower. (0)

$23.50 tolerance violation.  Although $30 is paid by the seller, it is included in tolerance testing unless customarily paid by the seller in that state.  Note:  Seller's CD reflects $30 Power of Attorney to Register of Deeds in section E.

Reviewer Comment (2017-02-22): Received evidence that POA is for seller and is a seller paid fee.

02/22/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201288664

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $382.50 exceeds tolerance of $153.00.  Insufficent or no cure was provided to the borrower. (7200)

Reviewer Comment (2017-02-08): Lender cured on the final CD with a $229.50 tolerance cure.

02/08/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201288665

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.04980% or Final Disclosure APR of 7.05000% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201288665

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201288665

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

22 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201288666

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

17 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201288666

Compliance

Compliance

Miscellaneous Compliance

Paid To party cannot be determined on the Closing Disclosure. For compliance testing purposes, Paid To of Lender will be considered in lieu of UTD.

Date Issued:

Missing payee name on appraisal fee

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201288666

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.45190% or Final Disclosure APR of 7.45200% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201288666

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.45190% or Final Disclosure APR of 7.45200% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201288666

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Seller Credit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Seller Credit that does not match the Seller Credit from the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Summary on page 3 shows in L-08 seller credit of $630, but amt not shown in Calculating Cash to Close "Final" column for seller credits.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201288666

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201288666

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on[MM/DD/YYYY] reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section. (Final/[MM/DD/YYYY])

appraisal fee missing payee name

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201288666

Credit

Loan Package Documentation

Closing / Title

Missing Document: Rider - Other not provided

Legal description rider to security instrument missing

Reviewer Comment (2017-02-10): Received copy of Rider.

02/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201288667

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

File is missing final executed CD for sale of current residence evidencing proof of funds receipt of $.

Reviewer Comment (2017-02-13): Received copy of CD.  Assets are fine.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201288667

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.43340% or Final Disclosure APR of 8.43300% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201288667

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $95,775.10, final CD shows $11,940.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201288668

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

22% DTI on this full documentation loan < 50% guideline max - 28% below program guideline maximum

Reviewer Comment (2017-02-08): Client elects to waive.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201288668

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.61830% or Final Disclosure APR of 7.66000% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201288668

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-14): Data correct on subsequent CDs (SFIG).

02/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201288669

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.21600% or Final Disclosure APR of 6.21600% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201288669

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.21600% or Final Disclosure APR of 6.21600% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201288669

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

The [MM/DD/YYYY] initial LE is for transactions with sellers, all other LE's and CD's are for transactions without sellers.

Reviewer Comment (2017-02-08): Data was corrected on subsequent disclosures

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201288669

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

The reserves, 7 months, are in excess of the program requirements of 3 months. Note: review finds 5.07 months. [REDACTED] has an excellent rating for past 36 months. Not using income with [KAREN YEE] for B2 which is approx. $1197 a month.

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201288669

Credit

Credit

Misc

Credit Exception:

Lender approved exception for the use of Non Traditional Credit on a cash out transaction.

The reserves, 7 months, are in excess of the program requirements of 3 months. Note: review finds 5.07 months. [REDACTED] has an excellent rating for past 36 months. Not using income with [KAREN YEE] for B2 which is approx. $1197 a month.

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201288669

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Disposable income discrepancy.

Lender approved exception.

The reserves, 7 months, are in excess of the program requirements of 3 months. Note: review finds 5.07 months. [REDACTED] has an excellent rating for past 36 months. Not using income with [KAREN YEE] for B2 which is approx. $1197 a month.

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201288670

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

36% DTI on this full documentation loan < 50% guideline max - 14% below program guideline maximum

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201288670

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.86920% or Final Disclosure APR of 7.86900% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.375%

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201288670

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-02): Received final CD reflecting seller paid fees.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201288670

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-02-08): This was cured at settlement.

02/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201288670

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201288671

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201288671

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.98750% or Final Disclosure APR of 7.98800% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201288671

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201288671

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-02-13): Received evidence that borrower received disclosure within timing requirements.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201288671

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

37% DTI on this full documentation loan < 50% guideline max - 13% below program guideline maximum

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201288672

Compliance

Compliance

Federal Compliance

Other Income - Not to be used for qualifying

Qualified Mortgage (Dodd-Frank 2014): Income used to qualify borrower(s) not permitted for use under Appendix Q. ( (employer unknown)/Asset Depletion)

Asset Depletion is not an approved income source for Appendix Q.

Reviewer Comment (2017-02-17): Designation switched to Non-QM

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201288672

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.34180% or Final Disclosure APR of 6.34200% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201288672

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-17): Designation switched to Non-QM

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201288672

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Guideline variance approved by lender at time of origination. Excess Reserves. Guideline variance approved by lender at time of origination, DTI less then maximum allowed. Borrower on this full doc documentation loan has a residual income of $2,307.35.

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201288672

Credit

Credit

Misc

Credit Exception:

Lender approved exception:  Per guidelines, use of retirement accounts for asset depletion requires borrower to be 59 1/2, borrower has not attained that age yet and lender used IRA accounts at 85% value for asset depletion to qualify.

Guideline variance approved by lender at time of origination. Excess Reserves. Guideline variance approved by lender at time of origination, DTI less then maximum allowed. Borrower on this full doc documentation loan has a residual income of $2,307.35.

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201288672

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $21,298.79.  Borrower's CD reflects $18,728.49.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201288672

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-17): Designation switched to Non-QM

02/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201289320

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

6 months > required 3 months.

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201289320

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201289320

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2017-02-09): Lender cured on re-disclosed LE dated [MM/DD/YYYY] and subsequent LE's and CD's using a consistent table usage.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201289320

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.43130% or Final Disclosure APR of 6.43100% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201289321

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

31% DTI on this full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201289321

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.95950% or Final Disclosure APR of 6.96000% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.375%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201289321

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $3,835.00, final CD shows $10,775.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201289322

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Erroneous Reg ID 2924. The F. Prepaids Homeowner's Insurance Premium includes a one time $25.00 service charge. The amounts disclosed in section G do not include the one time fee.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201289322

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201289322

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No VCC found for increase in fees on 1/10 LE.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201289322

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Administration Fee.  Fee Amount of $1,350.00 exceeds tolerance of $949.00.  Insufficent or no cure was provided to the borrower. (7355)

No VCC found for increase in fee.

Reviewer Comment (2017-03-01): Cure provided at closing. Reviewer Comment (2017-02-21): Rebuttal from lender states that lender credit covered this violation.  There are a total of $743.54 in tolerance violations and only $443.54 in lender credits.  Once aggregate of violations is remedied, then all tolerance violations will be cured.

03/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201289322

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

No VCC found for increase in fee.

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/27/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201289322

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $342.54 exceeds tolerance of $150.00.  Insufficent or no cure was provided to the borrower. (7520)

No VCC found for increase in fee on 1/10 LE.

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/27/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201289322

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

45 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201289323

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.19110% or Final Disclosure APR of 7.19100% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201289323

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.19110% or Final Disclosure APR of 7.19100% is in excess of allowable threshold of APOR 3.56% + 2.5%, or 6.06000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201289323

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $250.00 exceeds tolerance of $125.00 plus 10% or $137.50.  Insufficient or no cure was provided to the borrower. (0)

Per final CD and Seller final CD, borrower paid $125 for recording Mortgage and Seller paid $125 to record the Deed; however, in subject property state buyer is responsible for the Mortgage and Deed recording with seller only responsible for recording documents to remove encumbrances.

Reviewer Comment (2017-02-23): Received corrected CD with up to date recording fees, validated by settlement statement, which are within tolerances.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201289323

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Guideline variance approved by lender at time of origination. Based on $314K and monthly PITI, reserves are approximately $8K, which covers 3 years of reserves. Guideline variance approved by lender at time of origination. Debt ratio is 37.75% compared to program max of 50%.

Reviewer Comment (2017-02-10): Client elects to waive.

02/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201289323

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception

Guideline variance approved by lender at time of origination. Based on $314K and monthly PITI, reserves are approximately $8K, which covers 3 years of reserves. Guideline variance approved by lender at time of origination. Debt ratio is 37.75% compared to program max of 50%.

Reviewer Comment (2017-02-10): Client elects to waive.

02/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201289323

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title and Escrow agent fees listed in section B and title and escrow agent not reflected on SSPL as provider and should be in section C.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201289323

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201289324

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34.7% DTI on this (Full) documentation loan < 50% guideline max 726 representative FICO score > 660 guideline minimum Borrower on this (Full) documentation loan has a disposable income of $11,104.83.

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201289324

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.09070% or Final Disclosure APR of 6.09100% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201289324

Credit

Credit

Misc

Credit Exception:

Lender Approved Exception to approve the loan with gap in housing longer than 3 months.

34.7% DTI on this (Full) documentation loan < 50% guideline max 726 representative FICO score > 660 guideline minimum Borrower on this (Full) documentation loan has a disposable income of $11,104.83.

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201289325

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

33% DTI on this full documentation loan < 50% guideline max - 17% below program guideline maximum

Reviewer Comment (2017-02-13): Client elects to waive.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201289325

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.92400% or Final Disclosure APR of 7.93400% is in excess of allowable threshold of APOR 3.56% + 1.5%, or 5.06000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201289325

Compliance

Compliance

State Compliance

(TX50(a)(6)) Texas Cash-out Loan  (Acknowledgment of Fair Market Value Disclosure Not Signed by the Lender)

Texas Constitution Section 50(a)(6): Acknowledgment of the Fair Market Value not properly executed by the Lender.

Reviewer Comment (2017-02-21): Received document executed by all parties. Reviewer Comment (2017-02-15): Document sent in is Notice Concerning Extensions of Credit.  Exception is for Acknowledgment of the Fair Market Value executed by the lender (file contains document executed by borrowers).

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

To Remediate: Lender must sign the AFMV.  Best practices would be to deliver to the borrower the required disclosure signed by the lender.

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201289326

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-02-17): Designation switched to Safe Harbor QM

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201289326

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TILA-RESPA Integrated Disclosure: Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201289326

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $855.00 exceeds tolerance of $695.00.  Sufficient or excess cure was provided to the borrower at Closing. (73196)

Reviewer Comment (2017-02-09): Cured at closing.

02/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201289326

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $8,206.70 exceeds tolerance of $7,113.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-02-09): Cured at closing.

02/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201289326

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM matches the Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-02-17): Designation switched to Safe Harbor QM

02/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201289327

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.13510% or Final Disclosure APR of 8.13500% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201289327

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201289327

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $550.00.  Insufficent or no cure was provided to the borrower. (7507)

Reviewer Comment (2017-02-10): Cured at closing.

02/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201289327

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Reviewer Comment (2017-02-10): Cured at closing.

02/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201289327

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201289327

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

QM qualification requires the use of the maximum rate in the first 5 years method.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201289327

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Fee collected but no report provided.

14 months reserves > 6 months guideline minimum

Reviewer Comment (2017-02-16): Client elects to waive. Reviewer Comment (2017-02-14): Received copy of CDA but value is Indeterminate.  3rd Party valuation is required to substantiate appraised value.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201289327

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-15): Designation switched to Non-QM

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201289328

Credit

Assets

Asset Calculation / Analysis

AUS Findings: Available for Reserves discrepancy.

Lender approved excepiton

Significant residual income of $4,052.74 in excess of required of $1,650. DTI of 35% is significantly lower than 43%

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201289328

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Significant residual income of $4,052.74 in excess of required of $1,650. DTI of 35% is significantly lower than 43%

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201289328

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201289328

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.94200% or Final Disclosure APR of 7.94200% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201289328

Compliance

Compliance

Federal Compliance

TRID non-compliant:  There is a partially completed TRID disclosure in file, which is insufficient to complete testing.

Two CD's in file with closing dates of[MM/DD/YYYY] &[MM/DD/YYYY] and no issue or disbursement date that are largely incomplete.

Reviewer Comment (2017-02-15): Received attestation that disclosure was produced by title and never presented to borrower.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201289328

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender approved exception

Significant residual income of $4,052.74 in excess of required of $1,650. DTI of 35% is significantly lower than 43%

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201289329

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved a DTI exception to 54.97%; however, actual DTI is 55.13%.  Discrepancy in debt ratio due to calculation of monthly homeowner's insurance premium. U/W used $; however actual monthly premium is $.

Housing payment history 0x30 for 53 months. 30 months reserves > 3 months guideline minimum - borrowers have verified reserves of $$500,965.84.

Reviewer Comment (2017-02-10): Client elects to waive.

02/10/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201289329

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.31690% or Final Disclosure APR of 7.32000% is in excess of allowable threshold of APOR 4.06% + 2.5%, or 6.56000%.  Non-Compliant Higher Priced Mortgage Loan.

Emailed Lead regarding High priced loan.

Reviewer Comment (2017-02-10): All guideline violations have been addressed by lender.

02/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201289329

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-02-10): All guideline violations have been addressed by lender.

02/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201289329

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-10): All guideline violations have been addressed by lender.

02/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201289329

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-10): All guideline violations have been addressed by lender.

02/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201289329

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.31690% or Final Disclosure APR of 7.32000% is in excess of allowable threshold of APOR 4.06% + 2.5%, or 6.56000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Home Improvement

A

A

A

A

A

Non QM

Non QM

No

C

B

201289330

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

15 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-07): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive. Buyer Comment (2017-03-06): 2nd upload is the Full Pkg. JF

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201289330

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.65130% or Final Disclosure APR of 7.65100% is in excess of allowable threshold of APOR 4.36% + 2.5%, or 6.86000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201289330

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.65130% or Final Disclosure APR of 7.65100% is in excess of allowable threshold of APOR 4.36% + 2.5%, or 6.86000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201289330

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/137123)

Tax Cert  and Final CD reflects 6 months taxes at $3979.44 x 2 / 12 = $663.24, however Final CD reflects monthly taxes of  $565.10.

Reviewer Comment (2017-03-02): Correct tax amount used on final CD.  No violation.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201289330

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/137123)

Tax Cert  and Final CD reflects 6 months taxes at $3979.44 x 2 / 12 = $663.24, however Final CD reflects monthly taxes of  $565.10.

Reviewer Comment (2017-03-02): Correct tax amount used on final CD.  No violation.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201289330

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Closing Costs Paid At Closing

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Costs Paid at Closing that does not match the Total Closing Costs (Borrower-Paid) from page 2. (Final/[MM/DD/YYYY])

Summaries of Transactions reflects $7062.27.  Section J on page 2 reflects $7126.17.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201289330

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for $1394.02 decreased Lender Credit was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201289330

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $51,616.91.  Borrower's CD reflects $536,014.96.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201289330

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $8.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7579)

The CD reports a RESPA cure of $100 which is the total of the Flood Cert and Tax Service Fee's that were not previously disclosed.

Reviewer Comment (2017-02-09): Final CD reflects $100 Lender Credit for toleranc cures.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201289330

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7580)

The CD reports a RESPA cure of $100 which is the total of the Flood Cert and Tax Service Fee's that were not previously disclosed.

Reviewer Comment (2017-02-09): inal CD reflects $100 Lender Credit for toleranc cures.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201289330

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/[MM/DD/YYYY])

Report date .  Effective date .  Provided date

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201289330

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-8,104.98  is less than amount of binding Lender Credit previously disclosed in the amount of $-9,499.00. (9300)

First Loan Estimate reflects $9499, Initial CD reflects $9499.18 Lender Credit (loan was locked) and Final CD reflects $8104.98 Lender Credit.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.

Reviewer Comment (2017-03-02): Full credit was applied at closing.  Remainder was applied on page 3 and verified through settlement statement.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201289331

Compliance

Compliance

Federal Compliance

Flood Insurance Escrow - Flood not Escrowed for Property in Flood Zone

Loan originated post December 2015, the subject property  is in a flood zone, flood insurance is not escrowed.

Reviewer Comment (2017-03-29): Received evidence that flood insurance is included in HOA.

03/29/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

N/A

No

C

B

201289331

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

The Final Closing Disclosure reflects seller paid fees of $6,374. The Seller Closing Disclosure reflects seller paid fees of $7,064.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

C

B

201289331

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $655.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-10): Cured at closing.

02/10/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

N/A

Yes

C

B

201289331

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Subject is a non-warrantable condo with 407 sq ft GLA. Lender approved exception in the loan file.

35.194% DTI on this Full documentation loan < 43% guideline max - 7.806% below program guideline maximum Borrower on this Full documentation loan has a disposable income of $9,698.

Reviewer Comment (2017-02-10): Client elects to waive.

02/10/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

No

C

B

201289331

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,809.60 exceeds tolerance of $1,761.75.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-02-10): Cured at closing.

02/10/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

N/A

Yes

C

B

201300303

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

16 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-13): Client elects to waive.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201300303

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.95890% or Final Disclosure APR of 7.95900% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201300303

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-14): File switched to Non-QM

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201300303

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller at Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

CD reflects $171,834.94, calculates to be $171,639.94.  (Lender included $195 Title Search fee in calculations).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201300303

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Seller Paid - Before Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Seller Before Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

CD reflects $2072.16, calculates to be $2267.16.  (Lender did not include $195 Title Search fee in calculations)

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201300303

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $18,967.  Borrower's CD reflects $173,907.10.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201300303

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

QM adjusted DTI total of 43.077% is based on the Max Rate 5 year Periodic P&I

Reviewer Comment (2017-02-14): File switched to Non-QM

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201300303

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-02-14): File switched to Non-QM

02/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201300304

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved.

Residual income of $7,539 in excess of required of $6,350. 7 additional months of reserves over guideline requirement of 3 months. LTV of 70% below maximum of 85% 0x30x36 exceeds required of 0x30x24 by 12 months additional on time housing history Housing decrease via rate from 9.499 to 5.625 and P& from $6,474 to $4,605.

Reviewer Comment (2017-02-13): Client elects to waive.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201300304

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,000.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-13): Cured at closing.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201300304

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-13): All guideline violations have been addressed by lender.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201300304

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI > 50%.  Lender approved.

Reviewer Comment (2017-02-13): All guideline violations have been addressed by lender.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201300305

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Residual Income required is $1850. Actual is $7495.58 DTI Ratio is 19%. Required DTI is 43%

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201300305

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.71460% or Final Disclosure APR of 7.71500% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201300305

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Documents are signed on [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201300305

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Verified error. Disclosure states 2 months, but should be 12 months.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201300305

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201300305

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $115.00 exceeds tolerance of $71.00 plus 10% or $78.10.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-02-13): Cured at closing.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201300305

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $3,955.69 exceeds tolerance of $3,723.00.  Sufficient or excess cure was provided to the borrower at Closing. (7200)

Reviewer Comment (2017-02-13): Cured at closing.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201300305

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Residual Income required is $1850. Actual is $7495.58 DTI Ratio is 19%. Required DTI is 43%

Reviewer Comment (2017-02-13): Client elects to waive.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201300306

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee charged but no report provided.

54% LTV < 70% guideline max

Reviewer Comment (2017-03-02): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201300306

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.60430% or Final Disclosure APR of 8.61600% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201300306

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-02-16): Received evidence that borrower received disclosure within timing requirements.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201300306

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201300306

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-14): VCC regarding increased loan amount received.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201300306

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $1,526.50 exceeds tolerance of $1,397.00.  Insufficent or no cure was provided to the borrower. (7200)

Loan locked on[MM/DD/YYYY] at .75% discount points, points increased to 1% on[MM/DD/YYYY] with a COC indicating loan amount decreased which is not a valid COC for an increase in discount point percentage.

Reviewer Comment (2017-03-14): VCC regarding increased loan amount received.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201300307

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2017-02-13): Lender cured on re-disclosed LE dated [MM/DD/YYYY] and subsequent LE's and CD's using consistent table "With Seller".

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201300307

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.62010% or Final Disclosure APR of 6.62000% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201300307

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

The Home Loan Toolkit was provided on [MM/DD/YYYY] vs. application date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201300307

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $14,906, while closing CD seller's fees total $204,560.47.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201300307

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34.27% DTI on this Full documentation loan < 50% guideline max - 15.73% below program guideline maximum 12.45 months reserves > 9 months reserves guideline min - 3.45 months above program guideline minimum

Reviewer Comment (2017-02-13): Client elects to waive.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201300308

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

12 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-13): Client elects to waive.

02/13/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201300308

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Borrower Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Borrower at Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

Final CD reflects $200 Title - Endorsement fee as paid by borrower before closing and includes this amount in the totals for paid by borrower at closing.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201300308

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Borrower Paid - Before Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed Total Closing Costs (Paid by Borrower Before Closing) that does not match sum of fees. (Final/[MM/DD/YYYY])

Final CD reflects $200 Title - Endorsement fee as paid by borrower before closing and does not include this amount in the totals for paid by borrower before closing.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201300309

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Significant excess residual income of $5,246.05 ($3,150 required, $8,396.05 verified) Mortgage shows pay  history of 53 months with 2x30 which would meet HOA program guidelines, but due to lower FICO pushes to Fresh Start

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive. Buyer Comment (2017-02-14): Please disregard upload done in error.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201300309

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.53480% or Final Disclosure APR of 8.53500% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201300309

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender approved exception

Significant excess residual income of $5,246.05 ($3,150 required, $8,396.05 verified) Mortgage shows pay  history of 53 months with 2x30 which would meet HOA program guidelines, but due to lower FICO pushes to Fresh Start

Reviewer Comment (2017-02-13): Client elects to waive.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201300310

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

96 months reserves > 9 months guideline minimum

Reviewer Comment (2017-02-13): Client elects to waive.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201300310

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.18990% or Final Disclosure APR of 6.19000% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

HPML per lender, page

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201300310

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD shows $327,184.20, final CD shows $422,544.65.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201300310

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $57.39 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-02-13): This was cured at settlement.

02/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201310593

Compliance

Compliance

Federal Compliance

RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

No

C

B

201310593

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

710 representative FICO score > 660 guideline minimum - 50 points above guideline minimum 34.08% DTI on this (Documentation Type) documentation loan < 50% guideline max - 15.92% below program guideline maximum

Reviewer Comment (2017-02-14): Client elects to waive.

02/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

No

C

B

201310593

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.73070% or Final Disclosure APR of 8.73600% is in excess of allowable threshold of APOR 4.12% + 1.5%, or 5.62000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201310593

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $7,265.56, while closing CD seller's fees total $7,906.21.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201310593

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $75.00 exceeds tolerance of $50.00 plus 10% or $55.00.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Sufficient cure provided on final CD.

Reviewer Comment (2017-02-14): Cured at closing.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

Yes

C

B

201310593

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-02-27): Designation switched to Rebuttable Presumption.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201310594

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $11,561.60 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $13,544.00.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

B

B

201310594

Credit

Assets

Asset Calculation / Analysis

Guideline Requirement: Available for Reserves discrepancy.

Borrower on this full documentation loan has a disposable income of $3370

Reviewer Comment (2017-02-14): Client elects to waive.

02/14/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

Non QM

N/A

No

B

B

201310594

Credit

Credit

Misc

Credit Exception:

BK Discharge less than 2 years from application.

Borrower on this full documentation loan has a disposable income of $3370

Reviewer Comment (2017-02-14): Client elects to waive.

02/14/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

Non QM

N/A

No

B

B

201310595

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

42% DTI on this full documentation loan < 50% guideline max - 8% below program guideline maximum

Reviewer Comment (2017-02-14): Client elects to waive.

02/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201310595

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.04960% or Final Disclosure APR of 8.05000% is in excess of allowable threshold of APOR 4.22% + 1.5%, or 5.72000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201310595

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $5,500.11  Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $5,556.70.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201310595

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201310595

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,459.13 exceeds tolerance of $594.00.  Insufficent or no cure was provided to the borrower. (8304)

Reviewer Comment (2017-02-13): Typical Seller paid Transfer Taxes for Deed at $.70 per $100 of sales price or $854.70 paid by Seller on final CD.  Buyer portion of Transfer Taxes of $604.43 exceeds 0% tolerance of $594 by $10.43 and was cured on the final CD with a $69.61 tolerance cure.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201310595

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $59.18 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-02-13): Lender cured on final CD with $69.61 tolerance cure which included the $59.18 cure for credit report.

02/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201310596

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.85270% or Final Disclosure APR of 5.85300% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-02-14): All guideline violations have been addressed by lender.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201310596

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-02-14): All guideline violations have been addressed by lender.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201310596

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-14): All guideline violations have been addressed by lender.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201310596

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-14): All guideline violations have been addressed by lender.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201310596

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.85270% or Final Disclosure APR of 5.85300% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201310596

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $200.00 exceeds tolerance of $151.00 plus 10% or $166.10.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-02-14): Cured at closing.

02/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201310596

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved Exception

Residual income of $6868.88 when requirement is $2700 for a difference of $4168.88 75% LTV when the qualify for 85% after the 5% LTV reduction 55 month primary payment history when only 24 months is required

Reviewer Comment (2017-02-14): Client elects to waive.

02/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201310596

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.85270% or Final Disclosure APR of 5.85300% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201317318

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

Evidence of earlier borrower receipt was not found in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201317318

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

Evidence of earlier borrower receipt was not found in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201317318

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $850.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-15): Lender gave borrower $415 credit at closing.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201317318

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $215.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-02-15): Lender gave borrower $415 credit at closing.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201317318

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

22 months reserves > 3 months guideline minimum - borrowers have verified reserves of $159,018.74. 721 representative FICO score > 680 guideline minimum - 41 points above guideline minimum Borrower on this full documentation loan has a disposable income of $4,474.91.

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201317318

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.47320% or Final Disclosure APR of 6.47300% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Non-Compliant Higher Priced Mortgage Loan.

Emailed Lead to advise of HPML issue.

Reviewer Comment (2017-02-15): All guideline violations have been addressed by lender.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201317318

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

ATR issue due to the calculation of income.

Reviewer Comment (2017-02-15): All guideline violations have been addressed by lender.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201317318

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Lender approved as Non QM; review came up with ATR Risk due to missing income docs and calculation of income.

Reviewer Comment (2017-02-15): All guideline violations have been addressed by lender.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201317318

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

ATR exception due to prior foreclosures and income documentation.

Reviewer Comment (2017-02-15): All guideline violations have been addressed by lender.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201317318

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201317318

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved at 51.433%

22 months reserves > 3 months guideline minimum - borrowers have verified reserves of $159,018.74. 721 representative FICO score > 680 guideline minimum - 41 points above guideline minimum Borrower on this full documentation loan has a disposable income of $4,474.91.

Reviewer Comment (2017-02-15): Client elects to waive.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201317318

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.47320% or Final Disclosure APR of 6.47300% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201317320

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

33% DTI on this full documentation loan < 50% guideline max - 17% below program guideline maximum

Reviewer Comment (2017-02-15): Client elects to waive.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201317320

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2017-02-15): Lender cured on re-disclosed LE dated[MM/DD/YYYY] and subsequent LE's and CD's with consistent table usage.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201317320

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.57940% or Final Disclosure APR of 8.57900% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201317320

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $69.61 exceeds tolerance of $45.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-02-15): Lender provided $116.61 credit at closing for increase in Closing Costs above legal limit.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201317320

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-15): Lender provided $116.61 credit at closing for increase in Closing Costs above legal limit.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201317322

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

22 months reserves > 9 months guideline minimum

Reviewer Comment (2017-02-15): Client elects to waive.

02/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201317322

Compliance

Compliance

Federal Compliance

RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201317322

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

The file does not contain the E-Consent Disclosure and the initial LE was electronically sent to the borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201317322

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.79680% or Final Disclosure APR of 7.83900% is in excess of allowable threshold of APOR 4.17% + 1.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201317322

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

Reviewer Comment (2017-02-28): Valid CoCs were received for the discount point.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201317322

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $7,821.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

No valid change of circumstance in the file.

Reviewer Comment (2017-02-28): Valid CoCs were received for the discount point. Reviewer Comment (2017-02-23): Received CoC from broker, however, details do not state that Discount Points went from $0 to $7821 (Interest Rate dependent charges line is not sufficient as it's not specific to the fee).

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201360009

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

The file did not contain a copy of the Home Loan Toolkit disclosure or proof the borrower received the disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360009

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

The only CD in the file was the final CD issued and signed on [MM/DD/YYYY].  Provide a copy of the initial CD delivered to the borrower at least 3 business days prior to closing.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360009

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

The file did not contain a copy of the CHARM Booklit or proof the borrower received the disclosure.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360009

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing the required desk review.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360009

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.76320% or Final Disclosure APR of 5.80500% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360009

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.76320% or Final Disclosure APR of 5.80500% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360009

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

The borrower's CD did not contain any seller paid fees.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360009

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360011

Credit

Credit

Misc

Credit Exception:

Missing verification of tax assessment amount.

Reviewer Comment (2017-03-21): Received Title Prelim verifying amount used.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360011

Credit

Loan Package Documentation

Application / Processing

HOA Error: HOA dues not provided.

Reviewer Comment (2017-03-07): Received copy of appraisal.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.33210% or Final Disclosure APR of 5.37700% is in excess of allowable threshold of APOR 3.19% + 1.5%, or 4.69000%.  Non-Compliant Higher Priced Mortgage Loan.

Missing appraisal and proof of receipt.

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Missing appraisal and proof of receipt.

Reviewer Comment (2017-03-20): Received copy of appraisal

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Missing appraisal and proof of receipt.

Reviewer Comment (2017-03-20): Received copy of appraisal

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Missing appraisal and proof of receipt.

Reviewer Comment (2017-03-20): Received copy of appraisal

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.33210% or Final Disclosure APR of 5.37700% is in excess of allowable threshold of APOR 3.19% + 1.5%, or 4.69000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on  [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note contains Assumption verbiage while CD states loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360011

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360011

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure  [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360011

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $718.00 exceeds tolerance of $705.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-02-17): Cured at closing.

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360011

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360011

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Missing verification/LOE  that borrower was living rent free.

Reviewer Comment (2017-03-10): Client has stated that a VOE is not required.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360011

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-07): Received copy of appraisal.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360011

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.33210% or Final Disclosure APR of 5.37700% is in excess of allowable threshold of APOR 3.19% + 1.5%, or 4.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure  [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No Seller Fees paid on the borrower's Closing Disclosure; seller CD disclosed $93,708.33 in seller paid fees.

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No Change of Circumstances provided in file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $310.00 exceeds tolerance of $200.00 plus 10% or $220.00.  Insufficient or no cure was provided to the borrower. (0)

No Change of Circumstance provided in file

Reviewer Comment (2017-03-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,600.00 exceeds tolerance of $1,000.00.  Insufficent or no cure was provided to the borrower. (7506)

No Change of Circumstance provided in file

Reviewer Comment (2017-03-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7507)

No Change of Circumstance provided in file

Reviewer Comment (2017-03-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $322.00 exceeds tolerance of $62.00.  Insufficent or no cure was provided to the borrower. (7580)

No Change of Circumstance provided in file

Reviewer Comment (2017-03-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360014

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on  [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $310.00 exceeds tolerance of $200.00 plus 10% or $220.00.  Sufficient or excess cure was provided to the borrower. (0)

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,600.00 exceeds tolerance of $1,000.00.  Sufficient or excess cure was provided to the borrower. (7506)

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7507)

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360014

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $322.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower. (7580)

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360015

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360015

Credit

Loan Package Documentation

Application / Processing

Valuation Error: APN Number not provided.

Valuation Type: Appraisal / Valuation Report Date: [MM/DD/YYYY]

Missing from appraisal.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

There are no seller paid fees disclosed on the final CD.  CD is not signed, estimated settlement statement provided disclosed seller fees in the amount of $26,900.00.

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier receipt not in file.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Closing Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Total Closing Costs that does not match Total Closing Costs (Borrower-Paid) on page 2. (Final/[MM/DD/YYYY])

Page 1 of the final CD reflects Total Closing Costs totalling vs. page 2 which reflects . CD with an issue date of [MM/DD/YYYY] not used for TRID testing since signed and dated by the borrower on [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Other Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Other Costs that does not match Total Other Costs (Borrower-Paid) on page 2. (Final/[MM/DD/YYYY])

Page 1 of the final CD reflects Loan Costs totalling  vs. page 2 which reflects  CD with an issue date of [MM/DD/YYYY] not used for TRID testing since signed and dated by the borrower on [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/139765)

Page 1 of the final CD reflects an Estimated Escrow payment of $1,451.84 vs. actual payment of $1,406.42.CD with an issue date of [MM/DD/YYYY] not used for TRID testing since signed and dated by the borrower on [MM/DD/YYYY].

Reviewer Comment (2017-02-20): Data correct on subsequent CDs (SFIG).

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/139766)

Page 1 of the final CD reflects an Estimated Escrow payment of $1,451.84 vs. actual payment of $,406.42.CD with an issue date of [MM/DD/YYYY] not used for TRID testing since signed and dated by the borrower on [MM/DD/YYYY].

Reviewer Comment (2017-02-20): Data correct on subsequent CDs (SFIG).

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/139767)

Page 1 of the final CD reflects an Estimated Escrow payment of $1,451.84 vs. actual payment of $1,406.42. CD with an issue date of [MM/DD/YYYY] not used for TRID testing since signed and dated by the borrower on [MM/DD/YYYY].

Reviewer Comment (2017-02-20): Data correct on subsequent CDs (SFIG).

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/139768)

Page 1 of the final CD reflects an Estimated Escrow payment of $1,451.84 vs. actual payment of $1,406.42. CD with an issue date of [MM/DD/YYYY] not used for TRID testing since signed and dated by the borrower on 05/16/201

Reviewer Comment (2017-02-20): Data correct on subsequent CDs (SFIG).

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/139765)

Page 1 of the final CD reflects an Estimated Total Monthly payment of $6,145  vs. actual payment of $6,099.58.CD with an issue date of [MM/DD/YYYY] not used for TRID testing since signed and dated by the borrower on [MM/DD/YYYY].

Reviewer Comment (2017-02-20): Data correct on subsequent CDs (SFIG).

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Page 1 of the final CD reflects cash to close of $463,493.58 vs. page 3 which reflects $463,492.58. CD dated [MM/DD/YYYY] not used in TRID testing due to signed by borrower on [MM/DD/YYYY].

Reviewer Comment (2017-02-20): Data correct on subsequent CDs (SFIG).

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Closing Costs Paid At Closing

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Costs Paid at Closing that does not match the Total Closing Costs (Borrower-Paid) from page 2. (Final/[MM/DD/YYYY])

Page 1 of the final CD reflects Total Closing Costs of $21,859.98 vs. page 2 which reflects $21,860.98. CD dated [MM/DD/YYYY] not used in TRID testing due to signed by borrower on [MM/DD/YYYY].

Reviewer Comment (2017-02-20): Data correct on subsequent CDs (SFIG).

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

CD disclosed the borrowers EMD under the adjustments column.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Value - Total Closing Costs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed the Final value of Total Closing Costs that does not match the Total Closing Costs (Borrower-Paid) from page 2. (Final/[MM/DD/YYYY])

Page 1 of the final CD reflects Total Closing Costs of $21,859.98 vs. page 2 which reflects $21,860.98. CD dated [MM/DD/YYYY] not used in TRID testing due to signed by borrower on [MM/DD/YYYY].

Reviewer Comment (2017-02-20): Data correct on subsequent CDs (SFIG).

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360015

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360017

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Closing Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Total Closing Costs that does not match Total Closing Costs (Borrower-Paid) on page 2. (Final/[MM/DD/YYYY])

Closing Disclosure Closing Costs  and Closing Disclosure Borrower Paid Total Costs J $

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Other Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Other Costs that does not match Total Other Costs (Borrower-Paid) on page 2. (Final/[MM/DD/YYYY])

Closing Disclosure Other Costs  and Closing Disclosure Borrower Paid Other Costs I

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Closing Disclosure Summaries Cash From Borrower Amount $520,865.76 and Closing Disclosure Final Cash To Close $521,993.26.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Value - Total Closing Costs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed the Final value of Total Closing Costs that does not match the Total Closing Costs (Borrower-Paid) from page 2. (Final/[MM/DD/YYYY])

Closing Disclosure Final Total Closing Costs $26,101.78 and Closing Disclosure Borrower Paid Total Costs J $24,974.28.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $112.00 exceeds tolerance of $62.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-03-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360017

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant: Payee for Title Notary Fee is not shown.

Reviewer Comment (2017-03-22): Corrected on subsequent CDs.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360017

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360018

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure  [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No Seller paid fees reflected on Closing Disclosures

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360018

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

No evidence provided to Borrower within 3 business days of application

2

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360018

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

TILA-RESPA Integrated Disclosure: Settlement Service Provider List did not provide at least one available provider for each settlement service borrower is entitled to shop for or inform borrower they may choose different provider from list.

Not complaint - Settlement Providers List is blank and does not show any vendors.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360018

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360018

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on  [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360019

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360019

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Acknowledgment is signed but not filled out.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360019

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.38890% or Final Disclosure APR of 5.43700% is in excess of allowable threshold of APOR 3.38% + 1.5%, or 4.88000%.  Non-Compliant Higher Priced Mortgage Loan.

Loan is higher priced per the QM findings report provided.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360019

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Evidence the the borrower was provided a copy of the appraisal has not been provided.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360019

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.38890% or Final Disclosure APR of 5.43700% is in excess of allowable threshold of APOR 3.38% + 1.5%, or 4.88000%.  Compliant Higher Priced Loan.

Loan is higher priced per the QM findings report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360019

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing date is blank on the CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360019

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Evidence of a cure has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360019

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $700.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee disclosed as $700.00 on the LE's, but disclosed as $750.00 on Final Closing Disclosure.

Reviewer Comment (2017-03-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360019

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $507.65 exceeds tolerance of $507.00.  Insufficent or no cure was provided to the borrower. (8304)

Evidence of a cure has not been provided. The fee was rounded down on the LE and should have been rounded up to $508.00.

Reviewer Comment (2017-03-22): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360019

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360019

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.38890% or Final Disclosure APR of 5.43700% is in excess of allowable threshold of APOR 3.38% + 1.5%, or 4.88000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360020

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant:  Missing payee for Notary Fee

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360020

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360020

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.37160% or Final Disclosure APR of 5.42800% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Mortgage Loan.

verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360020

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.37160% or Final Disclosure APR of 5.42800% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Loan.

verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360020

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AIR Table Minimum Interest Rate

TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Minimum Interest Rate that does not match the actual minimum interest rate for the loan. (Final/[MM/DD/YYYY])

CD reflects 4.325%. Note and ARM Rider are Silent.  Margin is 3.95%.

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360020

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Data field is blank

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360020

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

The borrower's CD disclosed $0 seller paid fees.  The settlement statement in the file verified seller paid fees of $19,490.60.

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360020

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360020

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/139969)

CD reflects $996, calculates to be $953.

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360020

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/139970)

CD reflects $996, calculates to be $953.

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360020

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected P&I Min Payment Adjustable Rate Subsequent Payments

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/139971)

CD reflects $996, calculates to be $953.

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360020

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360022

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.44390% or Final Disclosure APR of 5.50300% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Mortgage Loan.

Disclosure reflects APR as 5.503%; allowable threshold is 4.67%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360022

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.44390% or Final Disclosure APR of 5.50300% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Loan.

Disclosure reflects APR as 5.503%; allowable threshold is 4.67%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360022

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date as [MM/DD/YYYY], but transaction consummation (mortgage notary) date is [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360022

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Disclosure reflects Homeowner's Insurance Premium collected for 12 months in the amount of $2,476, however the insurance policy in file reflects annual premium is $2,411.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360022

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Evidence of being provided not in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360022

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees on the buyers Closing Disclosure is $6,256; seller paid fees on the sellers Closing Disclosure is $134,850.39.  Seller paid fees not listed on the borrowers Final CD,Withholding fee of $45, Notary fee of $175, Overnight fee of $50, 3R Report of $151.33, Buyout of $50,000, Withholding of $30,636, Energy/Water Complicance of $625, Geological Inspection of $123.95, Home Warranty of $460, Inspection of $90, Buyer Realtor Commission of $23,000,Seller Realtor Commission of $23,000 and Reimbursement for Locksmith of $238.11.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360022

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Evidence of being provided not in file.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360022

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360022

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on  [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360024

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.43640% or Final Disclosure APR of 5.48400% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360024

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.43640% or Final Disclosure APR of 5.48400% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360024

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Closing Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Total Closing Costs that does not match Total Closing Costs (Borrower-Paid) on page 2. (Final/[MM/DD/YYYY])

Verified amounts for section J do not reconcile from page 1 and page 2

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360024

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Other Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Other Costs that does not match Total Other Costs (Borrower-Paid) on page 2. (Final/[MM/DD/YYYY])

Verified amounts do not match from page 1 and page 2

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360024

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360024

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360024

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Verified amounts in cash to close table and summaries of transaction table do not match, due to difference in section J amounts.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360024

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Value - Total Closing Costs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed the Final value of Total Closing Costs that does not match the Total Closing Costs (Borrower-Paid) from page 2. (Final/[MM/DD/YYYY])

Verified amounts do not match, Section J amount is different on page 2 compare to pages 1 and 3

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360024

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360024

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360026

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.26600% or Final Disclosure APR of 5.29700% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360026

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.26600% or Final Disclosure APR of 5.29700% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360026

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360026

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360026

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for various 0% tolerance violations $100 was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360026

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360026

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

Appraisal fee disclosed as $500 on the LE dated[MM/DD/YYYY]; but disclosed as $600 on the Final Closing Disclosure.

Reviewer Comment (2017-03-13): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360026

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360026

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360026

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Non-TRID Compliant: Payee for Title Notary Fee is not shown.

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360026

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360028

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.32180% or Final Disclosure APR of 5.36800% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

The file is missing a copy of the appraisal report.

Reviewer Comment (2017-03-29): Appraisal was provided by the seller.

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Appraisal report was not provided.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Appraisal report was not provided

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.32180% or Final Disclosure APR of 5.36800% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller paid fees on the seller's CD were $37,756.70.  There were no seller paid fees on the borrower's CD.

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360028

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360028

Credit

Credit

Misc

Credit Exception:

Final 1003, declarations does not indicate if borrower has had ownership interest in a property. Cash to close from sale of REO.

Reviewer Comment (2017-03-22): Received updated 1003 with correct data.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360028

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

The file was missing a copy of the appraisal report.

Reviewer Comment (2017-03-13): Received copy of appraisal

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360028

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360028

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.32180% or Final Disclosure APR of 5.36800% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360029

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD reflects closing date of [MM/DD/YYYY], but actual consummation date is [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360029

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees disclosed as $3,300.00 on Borrower Final CD, but disclosed as $183,598.95 on Seller CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360029

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360029

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on  [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360032

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360032

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD reflects a closing date of [MM/DD/YYYY], consummation did not take place until[MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360032

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Final CD /  Sellers CD do  not reflect any seller paid costs.  Sellers settlement statement does indicate seller paid fees that are not disclosed on the CD.

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360032

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Tax service fee was disclosed as $62.00, actual charge at closing was $132.00.  Evidence of a cure has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360032

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $132.00 exceeds tolerance of $62.00.  Insufficent or no cure was provided to the borrower. (7580)

Tax service fee was disclosed as $62.00, actual charge at closing was $132.00.  Evidence of a cure has not been provided.

Reviewer Comment (2017-03-13): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360032

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360033

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360033

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.27840% or Final Disclosure APR of 5.30900% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360033

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.27840% or Final Disclosure APR of 5.30900% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360033

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Consummation date is [MM/DD/YYYY].  Final Closing disclosure reflects the closing date of [MM/DD/YYYY] with a signature date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360033

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360033

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360034

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360034

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD reflects a closing date of [MM/DD/YYYY], executed on [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360034

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

File does not contain evidence that the borrower was provided the CHARM booklet for ARMS

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360034

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on  [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360035

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360035

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Disclosure does not reflect a closing date.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360035

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller paid fees on the buyers Closing Disclosure is $0; seller paid fees on the sellers Closing Disclosure is $64,307.50.  Seller paid fees not listed on the borrowers Final CD, Termite Repair of $650, Archiving fee of $80, Endorsement fee of $25, Escrow fee of $2,380, Messenger fee of $40, Processing fee of $150, Sub Escrow fee of $62.50, Recording fee of $30, Transfer tax of $1,133, Hold of $200, Home Warranty of $325, Zone Disclosure of $99, Buyer Realtor Commission of $25,750, Seller Realtor Commission of $30,900, Stock Transfer of $75 and Owner's Title of $2,408.

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360035

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Evidence of being provided not in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360035

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Evidence of being provided not in file.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360035

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360037

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360037

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.28720% or Final Disclosure APR of 5.48100% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360037

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.28720% or Final Disclosure APR of 5.48100% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360037

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360037

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

The closing date field has been left blank on the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360037

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

The sellers CD has not been provided.  There are no seller paid fees disclosed on the combined CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360037

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360037

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

Rate lock has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360037

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360037

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TIP of 99.023% but calculated TIP is 96.401%, which is outside of .003% tolerance.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360037

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Missing VOR/LOE from borrower living rent free.

Reviewer Comment (2017-03-10): Client has stated that a VOE is not required.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360038

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.46630% or Final Disclosure APR of 5.52600% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Loan.

Disclosure reflects APR as 5.526%; allowable threshold is 4.7%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360038

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects closing date as[MM/DD/YYYY]; mortgage notary date is[MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360038

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller paid fees on the buyers Closing Disclosure is $0; seller paid fees on the sellers Closing Disclosure is $44,249.80.  Seller paid fees not listed on the borrowers Final CD, Doc Prep fee of $200, Escrow fee of $1,216, Delivery fee of $30, Messenger fee of $25, Notary fee of $20, Wire fee of $30, Transfer Tax of $558.80, Hazard Disclosure of $99, Home Warranty of $400, Buyer Realtor Commission of $29,210, Seller Realtor Commission of $11,430 and Owner's Title of $1,031.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360038

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Evidence of being provided not in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360038

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Evidence of being provided not in file.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360038

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360038

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.46630% or Final Disclosure APR of 5.52600% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Mortgage Loan.

Disclosure reflects APR as 5.526%; allowable threshold is 4.7%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360038

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360039

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360039

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.39610% or Final Disclosure APR of 5.44900% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Non-Compliant Higher Priced Mortgage Loan.

Loan is higher priced as indicated on the compliance report provided.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360039

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.39610% or Final Disclosure APR of 5.44900% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Loan.

Loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360039

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360039

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt has not been provided.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360039

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360039

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Evidence that the borrower was provided a copy of the appraisal has not been provided.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360039

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Evidence that the borrower was provided a copy of the appraisal has not been provided.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360039

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.39610% or Final Disclosure APR of 5.44900% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360040

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360040

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.54250% or Final Disclosure APR of 5.62500% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360040

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.54250% or Final Disclosure APR of 5.62500% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360040

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $26,427.45 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $473.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360040

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360041

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360041

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date[MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360041

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360041

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360041

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360041

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360041

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $4,233.00 exceeds tolerance of $3,700.00 plus 10% or $4,070.00.  Sufficient or excess cure was provided to the borrower. (0)

No Change of Circumstance provided in file

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360041

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360042

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360042

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.43130% or Final Disclosure APR of 5.46000% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360042

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.43130% or Final Disclosure APR of 5.46000% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360042

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360042

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360042

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360042

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360044

Credit

Loan Package Documentation

Application / Processing

Missing Document: Purchase Agreement / Sales Contract not provided

Reviewer Comment (2017-03-22): Received copy of sales contract.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

D

A

D

A

D

A

D

A

D

A

Non QM

Non QM

No

D

B

201360044

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

Interest rate lock form not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

D

B

201360044

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Appraisal not provided

Reviewer Comment (2017-03-13): Received copy of appraisal

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201360044

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Appraisal was not provided in imaged file.

Reviewer Comment (2017-03-13): Received copy of appraisal

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date[MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201360044

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Final CD did not captured Sellers fee.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

D

B

201360044

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.42560% or Final Disclosure APR of 5.46800% is in excess of allowable threshold of APOR 3.16% + 1.5%, or 4.66000%.  Compliant Higher Priced Loan.

Verified all fees and note inputs. No Attorney or other fees collected on Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

D

B

201360044

Credit

Loan Package Documentation

Application / Processing

Missing Document: Missing Lender's Final 1003

Reviewer Comment (2017-03-22): Received copy of Final 1003.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.42560% or Final Disclosure APR of 5.46800% is in excess of allowable threshold of APOR 3.16% + 1.5%, or 4.66000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

D

B

201360044

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201360044

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.42560% or Final Disclosure APR of 5.46800% is in excess of allowable threshold of APOR 3.16% + 1.5%, or 4.66000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

D

B

201360047

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360047

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360047

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360047

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $112.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as $62.00 on LE dated[MM/DD/YYYY], but disclosed as $112.00 on Final CD.

Reviewer Comment (2017-02-20): Lender provided $50.07 credit at closing for increase in Closing Costs above legal limit.

02/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360047

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note discloses that loan is assumable; Final CD shows assumption is not allowed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360051

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360051

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.43170% or Final Disclosure APR of 5.48000% is in excess of allowable threshold of APOR 3.16% + 1.5%, or 4.66000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360051

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.43170% or Final Disclosure APR of 5.48000% is in excess of allowable threshold of APOR 3.16% + 1.5%, or 4.66000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360051

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure  [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $32,122.95, while closing CD seller's fees total $-0-.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360051

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360051

Credit

Credit

Misc

Credit Exception:

Lender guideline requires additional identification when Permanent Resident Alien card is used as primary identification.  Utility or Insurance bill have not been provided.

Reviewer Comment (2017-03-20): Lender is allowed to use subject property HOI Dec Page for insurance bill.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360051

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

Rate lock has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360051

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on  [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360052

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360052

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure  [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360052

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Lender's compliance testing indicates an initial CD was sent and received by borrower on [MM/DD/YYYY] , page 190, but this CD was not provided for review.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360052

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $82.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as $82.00 on LE dated [MM/DD/YYYY], but disclosed as $92.00 on Final CD.

Reviewer Comment (2017-02-21): This was cured at settlement.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360052

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on  [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note disclosed that loan is assumable, but Final CD disclosed that loan will not be assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360053

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360053

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower:

Missing VVOE

Reviewer Comment (2017-03-13): Received copy of VVOE.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360053

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.48120% or Final Disclosure APR of 5.56400% is in excess of allowable threshold of APOR 3.17% + 1.5%, or 4.67000%.  Compliant Higher Priced Loan.

Disclosure reflects APR as 5.564%; allowable threshold is 4.67%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360053

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects closing date as[MM/DD/YYYY]; mortgage notary date is[MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360053

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Evidence of being provided not in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360053

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Disclosure is executed[MM/DD/YYYY]; closing date is[MM/DD/YYYY].

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360053

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.48120% or Final Disclosure APR of 5.56400% is in excess of allowable threshold of APOR 3.17% + 1.5%, or 4.67000%.  Compliant Higher Priced Mortgage Loan.

Disclosure reflects APR as 5.564%; allowable threshold is 4.67%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360053

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Evidence of being provided not in file.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360053

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360053

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Final closing Disclosure reflects assumption is not allowed.  Note reflects language that allows an assumption.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360055

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.73490% or Final Disclosure APR of 5.76400% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/140985)

Disclosure reflects ($945.68), but should be ($953.10).

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/140986)

Disclosure reflects ($945.68), but should be ($953.10).

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/140987)

Disclosure reflects ($945.68), but should be ($953.10).

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/140988)

Disclosure reflects ($945.68), but should be ($953.10).

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/140985)

Disclosure reflects ($4089.93), but should be ($4097.35).

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $20,000.00, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360055

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.73490% or Final Disclosure APR of 5.76400% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $23.02 exceeds tolerance of $21.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Fee disclosed as ($21.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($23.02) on Final Closing Disclosure.

Reviewer Comment (2017-02-21): Cured at closing.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as ($62.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($72.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-21): Cured at closing.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360055

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360055

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360056

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2017-03-20): Received copy of appraisal.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360056

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-21): Received CDA with value within tolerance.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360056

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-20): Received copy of appraisal. Reviewer Comment (2017-03-13): Received 442.  Missing original appraisal.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360056

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

The Final Closing Disclosure reflects a closing date of [MM/DD/YYYY]; the mortgage reflects a notary date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360056

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360056

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $122.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as ($62.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($122.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-21): Lender provided $60.08 credit at closing for increase in Closing Costs above legal limit.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360056

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360056

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360061

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Appraisal not provided.

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360061

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360061

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360061

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-03-15): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360061

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

ARM loan program disclosure provided [MM/DD/YYYY] not within 3 days of application date of[MM/DD/YYYY].

Reviewer Comment (2017-03-22): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-09): Unable to locate any open exceptions that uploaded documents pertain to.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360061

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360061

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360061

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $102.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as $62 on LE dated[MM/DD/YYYY], but disclosed as $102 on Final Closing Disclosure. Fee disclosed as $102 on CD dated [MM/DD/YYYY] but no valid COC was provided.

Reviewer Comment (2017-02-21): Cured at closing.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360061

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Appraisal not provided.

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360061

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Final closing Disclosure reflects assumption is not allowed.  Note reflects language that allows an assumption

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360063

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360063

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status.

Application date of [MM/DD/YYYY]. Disclosure provided [MM/DD/YYYY].

Reviewer Comment (2017-03-22): Received evidence that borrower's application date was after signing sales contract on 9/22.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360063

Compliance

Compliance

Federal Compliance

RESPA Servicing Disclosure:  Servicing Disclosure Statement Not Provided Within 3 Business Days of Application

RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Statement to applicant within three (3) business days of application.

Reviewer Comment (2017-03-22): Received evidence that borrower's application date was after signing sales contract on 9/22.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360063

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Final closing Disclosure reflects assumption is not allowed.  Note reflects language that allows an assumption.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360063

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-15): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360063

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360063

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Initial Loan Estimate disclosure is not in the file. Application date is [MM/DD/YYYY].  Earliest Loan Estimate is [MM/DD/YYYY].

Reviewer Comment (2017-03-22): Received evidence that borrower's application date was after signing sales contract on 9/22. Reviewer Comment (2017-03-08): LE received is same as submission file.  App date is 8/17 and LE is dated 9/26

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360063

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

Application date is [MM/DD/YYYY]. SSPL dated [MM/DD/YYYY]

Reviewer Comment (2017-03-22): Received evidence that borrower's application date was after signing sales contract on 9/22.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360063

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Application date of [MM/DD/YYYY].  ARM disclosure date is [MM/DD/YYYY]. No evidence of earlier delivery.

Reviewer Comment (2017-03-22): Received evidence that borrower's application date was after signing sales contract on 9/22.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360063

Credit

Credit

Misc

Credit Exception:

Missing evidence/LOE that borrower is living rent free.

Reviewer Comment (2017-03-08): Client states LOE not required.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360065

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360065

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.66260% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360065

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360065

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $21,744.78, while closing CD seller's fees total $503.80.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360065

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.66260% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360065

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360066

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2017-03-20): Received copy of appraisal.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68490% or Final Disclosure APR of 5.70800% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2017-03-20): Received copy of appraisal.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68490% or Final Disclosure APR of 5.70800% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360066

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $53,397.00 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $814.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360066

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360066

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-21): Received CDA with value within tolerance.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360066

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Missing appraisal.

Reviewer Comment (2017-03-20): Received copy of appraisal. Reviewer Comment (2017-03-14): Appraisal provided is not for this file.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360066

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Missing proof of receipt of appraisal.

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Missing proof of receipt of appraisal.

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360066

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68490% or Final Disclosure APR of 5.70800% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360067

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64840% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.29% + 1.5%, or 4.79000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360067

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $18,294.25, while closing CD seller's fees total $-0-.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360067

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

The settlement service provider disclosure has not been provided.  It appears that the borrower used the vendors provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360067

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360067

Credit

Credit

Misc

Credit Exception:

Lender guideline requires a utility or insurance bill as additional identification when the borrowers Permanent Resident Alien Card is used as primary identification.

Reviewer Comment (2017-03-14): Lender is allowed to use subject property HOI Dec Page for insurance bill.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360067

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64840% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.29% + 1.5%, or 4.79000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360067

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

Rate lock has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360067

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360068

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.67500% or Final Disclosure APR of 5.71100% is in excess of allowable threshold of APOR 3.22% + 1.5%, or 4.72000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360068

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.67500% or Final Disclosure APR of 5.71100% is in excess of allowable threshold of APOR 3.22% + 1.5%, or 4.72000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360068

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360068

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $50,540.00, while closing CD seller's fees total $-0-.

Reviewer Comment (2017-03-15): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360068

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360068

Credit

Credit

Misc

Credit Exception:

Lender guidelines require an additional identification documentation when Permanent Resident Alien Card is used as primary identification.  Utility bill or insurance bill have not been provided.

Reviewer Comment (2017-03-14): Lender is allowed to use subject property HOI Dec Page for insurance bill.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360068

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

Rate lock has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360069

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing date is blank.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360069

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360069

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360069

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

1003 Error: Citizenship Source Documentation  was not provided

Borrower is permanent resident alien. Guidelines reflect the primary identification is to be a valid permanent resident card that is not expired. Permanent resident card provided reflects card expired 8/19/2015.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360069

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Missing VOR/LOE from borrower living rent free.

Reviewer Comment (2017-03-10): Client has stated that a VOE is not required.

03/10/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360069

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note has assumable language, but final CD reflects it will not allow assumption.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360070

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360070

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD shows closing date of [MM/DD/YYYY], vs consummation date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360070

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360070

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as $62.00 on LE dated[MM/DD/YYYY], but disclosed as $72.00 on Final CD.

Reviewer Comment (2017-02-21): Cure was issued on Final CD issued to borrower.

02/21/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360070

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note disclosed that loan is assumable, but Final CD shows loan is not assumable.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360070

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360070

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360072

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360072

Compliance

Compliance

Federal Compliance

RESPA Disclosure -  List of Homeownership Counseling Organizations Older Than 30 days When Provided to Borrower

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations was older than 30 days when provided to borrower.

Homeownership Counseling List date of  is more than 30 days from when list was provided to borrower on .

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360072

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $38,845.38, while closing CD seller's fees total $-0-.

Reviewer Comment (2017-03-15): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360072

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt has not been provided.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360072

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68000% or Final Disclosure APR of 5.70800% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360072

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68000% or Final Disclosure APR of 5.70800% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360072

Credit

Credit

Misc

Credit Exception:

Lender guideline requires additional identification when Permanent Resident Alien card is used as primary identification.  Utility or Insurance bill have not been provided.

Reviewer Comment (2017-03-14): Lender is allowed to use subject property HOI Dec Page for insurance bill.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360072

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

Rate lock has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360073

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360073

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360073

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360073

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360074

Credit

Credit

Misc

Credit Exception:

Missing Mortgage statement for property located at to verify taxes and insurance are included in PITI reflected on the credit report.

Reviewer Comment (2017-03-14): Received same documentation as in original file.  Using $3446 as PI payment for worse case scenario.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360074

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360074

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

CD reflects not assumable.  Note reflects assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360074

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360074

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $23.02 exceeds tolerance of $20.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-02-21): Cure of 33.02 was provided on final CD, sufficient to cure tolerance violation of $3.02.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360074

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-21): Cure of 33.02 was provided on final CD, sufficient to cure tolerance violation of $30.00

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360074

Credit

Credit

Misc

Credit Exception:

Borrower's Permanent/Resident Alien card expired on , prior to application date of . Guidelines verify it must not be expired.

Reviewer Comment (2017-03-14): Received evidence that the card was extended until 5/17.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360075

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.71040% or Final Disclosure APR of 5.73600% is in excess of allowable threshold of APOR 3.15% + 1.5%, or 4.65000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360075

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.71040% or Final Disclosure APR of 5.73600% is in excess of allowable threshold of APOR 3.15% + 1.5%, or 4.65000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360075

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360075

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360075

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a negative fee amount. (Final/[MM/DD/YYYY])

Disclosure reflects a negative fee for the Title-Owner's Coverage Prem (Optional)  in Section H.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360075

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360076

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360076

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.66600% or Final Disclosure APR of 5.71000% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 5.50%, HPML per lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360076

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.66600% or Final Disclosure APR of 5.71000% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

Note rate is 5.50%, HPML per lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360076

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360076

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360076

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360076

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360076

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360078

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing date is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360078

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $15.00, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360078

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Change - Adjustments

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether there was a change in the Adjustments and Other Credits. (Final/[MM/DD/YYYY])

Closing Disclosure reflects change from ($0.00) to ($3988.59), however Did this Change is answered No.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360078

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360078

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360079

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360079

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.65350% or Final Disclosure APR of 5.68700% is in excess of allowable threshold of APOR 3.35% + 1.5%, or 4.85000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360079

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.65350% or Final Disclosure APR of 5.68700% is in excess of allowable threshold of APOR 3.35% + 1.5%, or 4.85000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360079

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing date not provided on Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360079

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360079

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360079

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360079

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Missing VOR/LOE from borrower living rent free.

Reviewer Comment (2017-03-10): Client has stated that a VOE is not required.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360079

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

CD reflects not assumable.  Note reflects assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360080

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360080

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date and signature date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360080

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360080

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

The file does not contain evidence that the borrower was provided with a copy of the CHARM booklet for ARM Loans

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360080

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360081

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360081

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360081

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360082

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64400% or Final Disclosure APR of 5.67700% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360082

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64400% or Final Disclosure APR of 5.67700% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360082

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD reflects a closing date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360082

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure. Title - Notary Fee for $60, City Documentary Tax for $1,203.75, County Documentary Tax for $588.50, JCP-NHD for $123.95, Real Estate Commission for $13,375, Real Estate Commission for $13,375 were reflected on the Seller's CD, however were not reflected on the Borrower's Final CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360082

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360082

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360082

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360082

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Missing VOR/LOE from borrower living rent free.

Reviewer Comment (2017-03-08): Client states LOE is not required.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360082

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

CD reflects not assumable.  Note reflects assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360082

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360083

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.78030% or Final Disclosure APR of 5.80400% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360083

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360083

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on [MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Interim/[MM/DD/YYYY])

Received on [MM/DD/YYYY] but consent provided on [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360083

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360083

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.78030% or Final Disclosure APR of 5.80400% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360083

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360083

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360083

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360087

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360087

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360087

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360087

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360087

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360087

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $102.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-21): Lender provided $40.00 credit at closing for increase in Closing Costs above legal limit.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360087

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360089

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360089

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.67410% or Final Disclosure APR of 5.70900% is in excess of allowable threshold of APOR 3.35% + 1.5%, or 4.85000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360089

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.67410% or Final Disclosure APR of 5.70900% is in excess of allowable threshold of APOR 3.35% + 1.5%, or 4.85000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360089

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360089

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360089

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note discloses that loan is assumable, but Final CD discloses that loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360090

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360090

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.65890% or Final Disclosure APR of 5.69300% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-14): Received copy of appraisal

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360090

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2017-03-14): Received copy of appraisal

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360090

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.65890% or Final Disclosure APR of 5.69300% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360090

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360090

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360090

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360090

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2017-03-22): Received copy of appraisal.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360090

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360090

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.65890% or Final Disclosure APR of 5.69300% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360091

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360091

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.66040% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.25% + 1.5%, or 4.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360091

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360091

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.66040% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.25% + 1.5%, or 4.75000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360091

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360091

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360091

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow -  Monthly Escrow Payment

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed the Monthly Escrow Payment that does not match the actual escrow payment for the loan. (Final/[MM/DD/YYYY])

Post-close CD reflects correct escrow amount.

Reviewer Comment (2017-02-22): Data correct on subsequent CDs (SFIG).

02/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360091

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant.  Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure: Courier/Overnight Fee $50, Notary Fee $150, Home Warranty $465, NHD $99, Real Estate Commissions $22,900, Technology Fee $200, and Total Due $439.59 were reflected on the Seller's CD, however were not reflected on the Borrower's Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360091

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Missing VOR/LOE from borrower living rent free.

Reviewer Comment (2017-03-10): Client has stated that a VOE is not required.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360091

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

CD reflects not assumable.  Note reflects assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360092

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD shows closing date of [MM/DD/YYYY], vs consummation date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360092

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360092

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt not found in file.

Reviewer Comment (2017-03-22): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-08): CD provided was in original submission.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360092

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Missing origination appraisal.

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360092

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Fully completed origination Appraisal was not provided.

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360092

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Total coverage is $. Shortfall of $23,750.00.

Reviewer Comment (2017-03-14): Received copy of appraisal.  Coverage is sufficient.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360092

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360092

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note disclosed that loan was assumable, but Final CD disclosed that loan was not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360092

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure of $198.02 was reflected, which is insufficient to cure total tolerance violations totaling $238.02.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360092

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $675.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee disclosed as $500.00 on LE dated[MM/DD/YYYY], but disclosed as $675.00 on Final CD. Tolerance cure issued at closing is insufficient for total tolerance violations.

Reviewer Comment (2017-02-22): Cured at closing.

02/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360092

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $23.02 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7520)

Fee was not disclosed on LE. Tolerance cure issued at closing is insufficient for total tolerance violations.

Reviewer Comment (2017-02-22): Cured at closing.

02/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360092

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $102.00 exceeds tolerance of $62.00.  Insufficent or no cure was provided to the borrower. (7580)

Fee disclosed as $62.00 on LE dated[MM/DD/YYYY], but disclosed as $102.00 on Final CD. Valid Change of Circumstance was not documented to allow for fee increase.  Tolerance cure issued at closing is insufficient for total tolerance violations.

Reviewer Comment (2017-03-14): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360093

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68600% or Final Disclosure APR of 5.73600% is in excess of allowable threshold of APOR 3.25% + 1.5%, or 4.75000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360093

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360093

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360093

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360093

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68600% or Final Disclosure APR of 5.73600% is in excess of allowable threshold of APOR 3.25% + 1.5%, or 4.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360093

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360094

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360094

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63470% or Final Disclosure APR of 5.65400% is in excess of allowable threshold of APOR 3.25% + 1.5%, or 4.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360094

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63470% or Final Disclosure APR of 5.65400% is in excess of allowable threshold of APOR 3.25% + 1.5%, or 4.75000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360094

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360094

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $40,015.50, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360094

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Disclosure reflects loan will not allow for assumption, however Note reflects assumption language.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360094

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360095

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360095

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64870% or Final Disclosure APR of 5.67100% is in excess of allowable threshold of APOR 3.25% + 1.5%, or 4.75000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360095

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64870% or Final Disclosure APR of 5.67100% is in excess of allowable threshold of APOR 3.25% + 1.5%, or 4.75000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360095

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

CD reflects not assumbale.  Note reflects assumable.  Data is still not accurate on Post Close CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360095

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).  Data is still not accurate on Post Close CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360095

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360095

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Change - Adjustments

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether there was a change in the Adjustments and Other Credits. (Final/[MM/DD/YYYY])

Closing Disclosure reflects change from ($0) to 1516.97), however Did this Change is answered No.  Data was corrected on Post Close CD but missing LOE to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360095

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Missing initial CD. Borrower electronically received CD on [MM/DD/YYYY]. Earliest CD in file is final CD issued on [MM/DD/YYYY].

Reviewer Comment (2017-03-08): Seller provided the initial CD.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360095

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360096

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $108,170.75, while closing CD seller's fees total $0.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360096

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 2933. No tolerance violation of Tax Service Fee (Life Of Loan) due to fee being properly disclosed on the [MM/DD/YYYY] re-disclosed LE in the amount of $202. Does not exceed tolerance.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360096

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $122.00 exceeds tolerance of $62.00.  Insufficent or no cure was provided to the borrower. (7580)

Missing VCC for 10/21 LE.

Reviewer Comment (2017-03-15): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/15/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360096

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360096

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Missing VOR/LOE from borrower living rent free.

Reviewer Comment (2017-03-10): Client has stated that a VOE is not required.

03/10/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360096

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

CD reflects not assumable.  Note reflects assumable.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360097

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360097

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360097

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63250% or Final Disclosure APR of 5.65900% is in excess of allowable threshold of APOR 3.22% + 1.5%, or 4.72000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360097

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360097

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-21): Lender provided $10.02 credit at closing for increase in Closing Costs above legal limit.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360097

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360097

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63250% or Final Disclosure APR of 5.65900% is in excess of allowable threshold of APOR 3.22% + 1.5%, or 4.72000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360097

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360099

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing Date is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360099

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $21,727.35, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360099

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,050.00 exceeds tolerance of $900.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Fee disclosed as ($900.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($1050.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-22): Cured at closing.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360099

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as ($62.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($92.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-22): Cured at closing.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360099

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,595.55 exceeds tolerance of $1,595.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Fee disclosed as ($1595.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($1595.55.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-22): Cured at closing.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360099

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360099

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Disclosure reflects loan will not allow for assumption, however Note reflects assumption language.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360101

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing the CDA or Desk Review

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360101

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.74840% or Final Disclosure APR of 5.77500% is in excess of allowable threshold of APOR 3.17% + 2.5%, or 5.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360101

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.74840% or Final Disclosure APR of 5.77500% is in excess of allowable threshold of APOR 3.17% + 2.5%, or 5.67000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360101

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360101

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360101

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $11,250.00 exceeds tolerance of $10,550.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-02-21): Lender gave borrower $1265 credit at closing.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360103

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360103

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.67710% or Final Disclosure APR of 5.69300% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360103

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Missing Initial Closing Disclosure provided to Borrower at least 3 business days prior to consummation

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360103

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

No evidence provided to Borrower within 3 business days of application.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from  that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360103

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.67710% or Final Disclosure APR of 5.69300% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360103

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360103

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360104

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360104

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63740% or Final Disclosure APR of 5.66700% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360104

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63740% or Final Disclosure APR of 5.66700% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360104

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360104

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360104

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Change - Adjustments

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether there was a change in the Adjustments and Other Credits. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360105

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360105

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Missing VOR/LOE from borrower living rent free.

Reviewer Comment (2017-03-10): Client has stated that a VOE is not required.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360105

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $82.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-21): Cure of $10 was provided on the final CD.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360105

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360105

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360105

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360106

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.61230% or Final Disclosure APR of 5.63100% is in excess of allowable threshold of APOR 3.22% + 1.5%, or 4.72000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360106

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note indicates loan is assumable; Final CD shows loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360106

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360106

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees reflected as $52,009.45 on Seller CD, but as $2,273.00 on Borrower Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360106

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360106

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status.

Evidence of earlier borrower receipt was not found in file.  App date 9/20, disclosure date 10/3.

Reviewer Comment (2017-03-22): Received confirmation that the application date is 10/3 the first 1003 that listed a property address.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360106

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.61230% or Final Disclosure APR of 5.63100% is in excess of allowable threshold of APOR 3.22% + 1.5%, or 4.72000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-22): Received confirmation that the application date is 10/3 the first 1003 that listed a property address.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360106

Compliance

Compliance

Federal Compliance

(Fed HPML Disclosure) Federal Higher-Priced Mortgage Loan (Right to Receive Cope of Appraisal)

TILA HPML Appraisal Rule (Dodd-Frank 2014):  Creditor did not provide "Right to Receive Copy" appraisal disclosure to consumer within three (3) business days of application.

Reviewer Comment (2017-03-22): Received confirmation that the application date is 10/3 the first 1003 that listed a property address. Reviewer Comment (2017-03-15): Received copy of Receipt of Appraisal.  Missing Right to Receive Appraisal disclosure from application.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360106

Compliance

Compliance

Federal Compliance

RESPA Servicing Disclosure:  Servicing Disclosure Statement Not Provided Within 3 Business Days of Application

RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Statement to applicant within three (3) business days of application.

Evidence of earlier borrower receipt was not found in file.  App date 9/20, disclosure date 10/3.

Reviewer Comment (2017-03-22): Received confirmation that the application date is 10/3 the first 1003 that listed a property address.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360106

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.  App date 9/20, disclosure date 10/3.

Reviewer Comment (2017-03-22): Received confirmation that the application date is 10/3 the first 1003 that listed a property address. Reviewer Comment (2017-03-09): Received same LE as in original file.  As mentioned in the exception, app date is 9/20 and disclosure date is 10/3.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360106

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.61230% or Final Disclosure APR of 5.63100% is in excess of allowable threshold of APOR 3.22% + 1.5%, or 4.72000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360107

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360107

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63800% or Final Disclosure APR of 5.68500% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360107

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63800% or Final Disclosure APR of 5.68500% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360107

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $545.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Fee disclosed as ($500.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($545.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-22): Cured at closing.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360107

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360107

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360107

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360109

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360109

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.66750% or Final Disclosure APR of 5.69200% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated by the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360109

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.66750% or Final Disclosure APR of 5.69200% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated by the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360109

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360109

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360109

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360109

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Change - Adjustments

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether there was a change in the Adjustments and Other Credits. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360110

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360110

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.79570% or Final Disclosure APR of 5.80900% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

Disclosure reflects APR as 5.809%; allowable threshold is 4.77%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360110

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.79570% or Final Disclosure APR of 5.80900% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Disclosure was executed on [MM/DD/YYYY]; closing date is [MM/DD/YYYY].  Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

The lender did not disclose the fees in the correct section.  The Title fees were listed in Section C on the Loan Estimates and then moved to Section B of the Final Closing Disclosure.  [REDACTED] is an unaffiliated 3rd party that is not on the Settlement Service Provider List. Fees were corrected on a Post Closing CD.

Reviewer Comment (2017-02-23): Fees were moved to the correct section on the post-close CD provided and issued on the disbursement date.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

Reviewer Comment (2017-02-23): Fees were moved to the correct section on the post-close CD provided and issued on the disbursement date.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee.  Fee Amount of $1,120.00 exceeds tolerance of $1,000.00.  Insufficent or no cure was provided to the borrower. (7561)

Fee shown in Section B and provider used was not on the SPPL list. Corrected on PCCD issued on [MM/DD/YYYY].

Reviewer Comment (2017-02-23): Fees were moved to the correct section on the post-close CD provided and issued on the disbursement date.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

Unable to determine if loan file contains evidence of borrower's consent to receive electronic documents due to missing information.

Reviewer Comment (2017-03-24): Reset

03/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

A

A

A

A

A

Non QM

Non QM

No

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360110

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

Non QM

Non QM

No

C

B

201360111

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.69930% or Final Disclosure APR of 5.72400% is in excess of allowable threshold of APOR 3.19% + 1.5%, or 4.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360111

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.69930% or Final Disclosure APR of 5.72400% is in excess of allowable threshold of APOR 3.19% + 1.5%, or 4.69000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360111

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.  The initial CD in the file was dated [MM/DD/YYYY]; however the file contained documentation that an additional CD was delivered on [MM/DD/YYYY].  Provide a copy of the initial CD sent to the borrower.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360111

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360111

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360112

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360112

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64980% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360112

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $53,613.75 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $935.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360112

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64980% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360112

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note discloses that loan is assumable, however Final CD states loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360114

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360114

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.65650% or Final Disclosure APR of 5.68100% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360114

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.65650% or Final Disclosure APR of 5.68100% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360114

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360114

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360114

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360116

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.65160% or Final Disclosure APR of 5.67000% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360116

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360116

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.65160% or Final Disclosure APR of 5.67000% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360116

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360116

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360116

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360117

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360117

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68010% or Final Disclosure APR of 5.69900% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360117

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68010% or Final Disclosure APR of 5.69900% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360117

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Initial CD was provided.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360117

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

Added [MM/DD/YYYY], initial CD was provided that was e-signed, missing e-sign consent.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

Non QM

Non QM

No

C

B

201360117

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360117

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360118

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360118

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360118

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.  The final CD was the only CD in the file.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360118

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360118

Compliance

Compliance

Federal Compliance

TRID non-compliant: Missing Seller's Closing Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360119

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360119

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68560% or Final Disclosure APR of 5.70700% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

Disclosure reflects APR as 5.707%; allowable threshold is 4.74%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360119

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68560% or Final Disclosure APR of 5.70700% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

Disclosure reflects APR as 5.707%; allowable threshold is 4.74%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360119

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360119

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360119

Compliance

Compliance

Federal Compliance

TRID non-compliant: Missing Seller's Closing Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360120

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360120

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.84610% or Final Disclosure APR of 5.89500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360120

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.84610% or Final Disclosure APR of 5.89500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360120

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360120

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360120

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360121

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360121

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.66610% or Final Disclosure APR of 5.70400% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360121

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.66610% or Final Disclosure APR of 5.70400% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360121

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360121

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360121

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360122

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.70440% or Final Disclosure APR of 5.74500% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360122

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.70440% or Final Disclosure APR of 5.74500% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360122

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360122

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $27,379.80, while closing CD seller's fees total $575.85.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360122

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Appraisal is missing from file.

Reviewer Comment (2017-03-29): The appraisal was provided.

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360122

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360122

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

The file was missing a copy of the appraisal.

Reviewer Comment (2017-03-22): Received evidence that borrower received appraisal within timing requirements. Reviewer Comment (2017-03-15): Received copy of appraisal.  Still missing proof of delivery.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360122

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360122

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.70440% or Final Disclosure APR of 5.74500% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360123

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360123

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360123

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.69160% or Final Disclosure APR of 5.71300% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360123

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360123

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $63,042.51 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $7,140.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360123

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.69160% or Final Disclosure APR of 5.71300% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360124

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/[MM/DD/YYYY])

Appraisal provided to borrower.  Appraisals in file show effective date of .  Report dates are . It appears the initial report was provided, with no evidence that revised report from 1 was provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360124

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68110% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360124

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68110% or Final Disclosure APR of 5.69500% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360124

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file. File documentation (pg 197, 262) indicates a CD was issued/received by borrower [MM/DD/YYYY], however file does not include any CDs dated [MM/DD/YYYY] for support.

Reviewer Comment (2017-03-09): Executed initial CD provided.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360124

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360124

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360124

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360125

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360125

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360125

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68730% or Final Disclosure APR of 5.69200% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360125

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Initial CD provided.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360125

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360125

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360125

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68730% or Final Disclosure APR of 5.69200% is in excess of allowable threshold of APOR 3.20% + 1.5%, or 4.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360125

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360125

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360125

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360126

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.61450% or Final Disclosure APR of 5.65100% is in excess of allowable threshold of APOR 3.29% + 1.5%, or 4.79000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360126

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.61450% or Final Disclosure APR of 5.65100% is in excess of allowable threshold of APOR 3.29% + 1.5%, or 4.79000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360126

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360126

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $47,851.95, while closing CD seller's fees total $6052.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360126

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360126

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as ($62.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($72.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-24): Cure provided on the final CD

02/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360126

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360127

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360127

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.79230% or Final Disclosure APR of 5.80800% is in excess of allowable threshold of APOR 3.30% + 2.5%, or 5.80000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360127

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.79230% or Final Disclosure APR of 5.80800% is in excess of allowable threshold of APOR 3.30% + 2.5%, or 5.80000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360127

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a negative fee amount. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-18): Exception cited in error based on Seller CD values

03/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360127

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360127

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360129

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360129

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.79790% or Final Disclosure APR of 5.80400% is in excess of allowable threshold of APOR 3.25% + 2.5%, or 5.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360129

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.79790% or Final Disclosure APR of 5.80400% is in excess of allowable threshold of APOR 3.25% + 2.5%, or 5.75000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360129

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Final closing Disclosure reflects assumption is not allowed.  Note reflects language that allows an assumption.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360129

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $55.04 exceeds tolerance of $22.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Cure of $33.04 was provided on final closing disclosure.

Reviewer Comment (2017-02-22): Lender provided $83.04 credit at closing for increase in Closing Costs above legal limit.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360129

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $112.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Cure of $50 was provided on final closing disclosure.

Reviewer Comment (2017-02-22): Lender provided $83.04 credit at closing for increase in Closing Costs above legal limit.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360130

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.72850% or Final Disclosure APR of 5.75800% is in excess of allowable threshold of APOR 3.18% + 1.5%, or 4.68000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360130

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.72850% or Final Disclosure APR of 5.75800% is in excess of allowable threshold of APOR 3.18% + 1.5%, or 4.68000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360130

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360130

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.  The only CD in the file was the final CD.

Reviewer Comment (2017-03-22): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-07): Uploaded CD already reviewed and was the basis of the exception.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360130

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360131

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360131

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68770% or Final Disclosure APR of 5.70800% is in excess of allowable threshold of APOR 3.18% + 1.5%, or 4.68000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360131

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68770% or Final Disclosure APR of 5.70800% is in excess of allowable threshold of APOR 3.18% + 1.5%, or 4.68000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360131

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Closing Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed Total Closing Costs that does not match Total Closing Costs (Borrower-Paid) on page 2. (Final/[MM/DD/YYYY])

Page 1 and calculating cash to close table on the final CD disclosed total closing costs of $, however Page 2 closing cost total is $

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360131

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Other Costs

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed Other Costs that does not match Total Other Costs (Borrower-Paid) on page 2. (Final/[MM/DD/YYYY])

Page 1 of the final CD disclosed loan costs of $ however loan costs on page 2 are $

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360131

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $54,107.47, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360131

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

On page three, Calculation Cash to Close reflects ($234,593.58), however Summaries reflects ($233,724.58).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360131

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Value - Total Closing Costs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed the Final value of Total Closing Costs that does not match the Total Closing Costs (Borrower-Paid) from page 2. (Final/[MM/DD/YYYY])

The final CD disclosed closing costs in section J of $15,037.07, calculating cash to close table disclosed closing costs of $15,906.07.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360131

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.  The only CD in the file was the final CD.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360132

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68630% or Final Disclosure APR of 5.69000% is in excess of allowable threshold of APOR 3.18% + 1.5%, or 4.68000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360132

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360132

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.  The final CD is the only CD in the file.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360132

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360132

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68630% or Final Disclosure APR of 5.69000% is in excess of allowable threshold of APOR 3.18% + 1.5%, or 4.68000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360133

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360133

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects closing date as 11/1/16; mortgage notary date is [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360133

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360133

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360134

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

The appraisal was not provided in the file.

Reviewer Comment (2017-03-15): Received copy of appraisal

03/15/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360134

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-21): Received CDA with value within tolerance.

03/21/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360134

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360134

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360134

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller CD fees total $0.00 and closing CD seller's fees total $0.00; however the estimated settlement statement in the file disclosed seller paid fees.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360134

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-15): Received copy of appraisal

03/15/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360134

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201360135

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360135

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.68770% or Final Disclosure APR of 5.70600% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360135

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $68,465.57 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360135

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360135

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.68770% or Final Disclosure APR of 5.70600% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360135

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-23): Lender provided $10.20 credit at closing for increase in Closing Costs above legal limit.

02/23/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360140

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360140

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.74220% or Final Disclosure APR of 5.74800% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360140

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.74220% or Final Disclosure APR of 5.74800% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360140

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $109,078.03 while closing CD seller's fees total $0.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360140

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-20): Received evidence that borrower received disclosure within timing requirements.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360140

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360141

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360141

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.69060% or Final Disclosure APR of 5.69400% is in excess of allowable threshold of APOR 3.21% + 1.5%, or 4.71000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360141

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.69060% or Final Disclosure APR of 5.69400% is in excess of allowable threshold of APOR 3.21% + 1.5%, or 4.71000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360141

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $27,861.98 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $2,902.80.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360142

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360142

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller CD does not reflect any fees, however the Estimated Settlement Statement reflects fees.  We will need the Final Seller CD.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360142

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360144

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.67980% or Final Disclosure APR of 5.79500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360144

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.67980% or Final Disclosure APR of 5.79500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360144

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360144

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $33,081.39 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360144

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360144

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360145

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360145

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63120% or Final Disclosure APR of 5.66500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360145

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360145

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing date on Final Closing Disclosure issued on [MM/DD/YYYY] is not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360145

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Verified with Final Closing Disclosure 1[MM/DD/YYYY] that no seller fees were paid in a transaction.  Missing Seller CD

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360145

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Missing initial CD received by borrower on [MM/DD/YYYY] per Electronic Disclosure. CD in file is final and issued on [MM/DD/YYYY].

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360145

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63120% or Final Disclosure APR of 5.66500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360145

Compliance

Compliance

Federal Compliance

TRID non-compliant: Missing Seller's Closing Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360148

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63370% or Final Disclosure APR of 5.64900% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360148

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63370% or Final Disclosure APR of 5.64900% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360148

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360148

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $30,953.95 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360148

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Missing Initial Closing Disclosure or 3-day Waiver

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360148

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360148

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-24): Lender credit $10.00 reflected on Closing Disclosure

02/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360148

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360151

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360151

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.81830% or Final Disclosure APR of 5.85200% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360151

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.81830% or Final Disclosure APR of 5.85200% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360151

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $29,576.04 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360151

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360152

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360152

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD disclosed the closing date as [MM/DD/YYYY]; actual closing date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360152

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Missing Final Seller CD, file only contains estimated settlement statement.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360152

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-27): Cure provided on the final CD

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360152

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360154

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360154

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63340% or Final Disclosure APR of 5.66000% is in excess of allowable threshold of APOR 3.30% + 1.5%, or 4.80000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360154

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63340% or Final Disclosure APR of 5.66000% is in excess of allowable threshold of APOR 3.30% + 1.5%, or 4.80000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360154

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360154

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360154

Credit

Credit

Misc

Credit Exception:

Missing the Primary identification of the Permanent Resident Alien Card per the guidelines.  There is only the borrower's driver's licence, social security card, and a notation of a credit card with # in the loan file.

Reviewer Comment (2017-03-15): Lender is allowed to use subject property HOI Dec Page for insurance bill.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360154

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $49,530.00, while closing CD seller's fees total $1056.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360154

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $82.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as ($62.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($82.00) on Final Closing Disclosure.

Reviewer Comment (2017-02-27): Cure provided on the final CD

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360156

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360156

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.75470% or Final Disclosure APR of 5.79300% is in excess of allowable threshold of APOR 3.30% + 1.5%, or 4.80000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360156

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.75470% or Final Disclosure APR of 5.79300% is in excess of allowable threshold of APOR 3.30% + 1.5%, or 4.80000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360156

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360156

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $20,906.50 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360156

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-20): Received evidence that borrower received disclosure within timing requirements.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360156

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360159

Compliance

Compliance

Federal Compliance

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360159

Compliance

Compliance

State Compliance

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360159

Compliance

Compliance

Federal Compliance

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360159

Compliance

Compliance

Federal Compliance

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360159

Compliance

Compliance

Federal Compliance

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360159

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360159

Compliance

Compliance

Federal Compliance

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360159

Property

Property - Appraisal

Appraisal Documentation

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360159

Credit

Loan Package Documentation

Application / Processing

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360159

Compliance

Compliance

Federal Compliance

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360160

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360160

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

1003 Error: Citizenship Source Documentation  was not provided

Borrower:

Copy of VISA is not in the file. Noted on 1003 Borrower has I-512 Working VISA.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360160

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360160

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360160

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360160

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360161

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360161

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.74940% or Final Disclosure APR of 5.75800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360161

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.74940% or Final Disclosure APR of 5.75800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360161

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Field is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360161

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $13,870.08 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360162

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360162

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.79940% or Final Disclosure APR of 5.82500% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360162

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.79940% or Final Disclosure APR of 5.82500% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360162

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM Rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360162

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360162

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $26,806.46 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360162

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Initial CD provided.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360164

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360164

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY] but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360164

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $90,014, while closing CD seller's fees total $10,540.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360164

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $36.04 exceeds tolerance of $24.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Fee disclosed as $24 on the LE dated [MM/DD/YYYY], but disclosed as $36.04 on Final Closing Disclosure.

Reviewer Comment (2017-02-27): Lender provided $12.04 credit at closing for increase in Closing Costs above legal limit.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360164

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360166

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

The appraisal is missing the 1004MC (Market Conditions).

Reviewer Comment (2017-03-15): Form not required.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360166

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63050% or Final Disclosure APR of 5.64700% is in excess of allowable threshold of APOR 3.28% + 1.5%, or 4.78000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360166

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63050% or Final Disclosure APR of 5.64700% is in excess of allowable threshold of APOR 3.28% + 1.5%, or 4.78000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360166

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  The Final CD incorrectly disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360166

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Sellers CD has not been provided.  Final combined CD does not disclose any seller paid fees.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360166

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $800.00 exceeds tolerance of $700.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Fee disclosed as $700 on the LE dated [MM/DD/YYYY], but disclosed as $800 on Final Closing Disclosure.  Evidence of a sufficient cure was provided on the final CD.

Reviewer Comment (2017-02-27): Lender provided $110.00 credit at closing for increase in Closing Costs above legal limit.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360166

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as $62 on the LE dated [MM/DD/YYYY], but disclosed as $72 on Final Closing Disclosure.  Evidence of a sufficient cure was provided on the final CD.

Reviewer Comment (2017-02-27): Lender provided $110.00 credit at closing for increase in Closing Costs above legal limit.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360166

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360166

Compliance

Compliance

Federal Compliance

TRID non-compliant: Missing Seller's Closing Disclosure.

Sellers CD has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360166

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Missing initial CD shown as received by borrower on [MM/DD/YYYY]. Final CD in file shows issue date of [MM/DD/YYYY].  Evidence of receipt 3 days prior to closing has not been provided.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360167

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360167

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.61040% or Final Disclosure APR of 5.62400% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360167

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $52,183.20 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360167

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.61040% or Final Disclosure APR of 5.62400% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360167

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360167

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

The final CD was the only CD provided in the file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360168

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360168

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Field is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360168

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $50,249.88 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360168

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360168

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360168

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-27): Lender provided $10.00 credit at closing for increase in Closing Costs above legal limit.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360171

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360171

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

1003 Error: Citizenship Source Documentation  was not provided

Borrower:

Two forms of secondary identification were provided.  Permanent Resident Alien card has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360171

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.80290% or Final Disclosure APR of 5.84300% is in excess of allowable threshold of APOR 3.28% + 1.5%, or 4.78000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360171

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.80290% or Final Disclosure APR of 5.84300% is in excess of allowable threshold of APOR 3.28% + 1.5%, or 4.78000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360171

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360171

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

The closing date is blank on the early and final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360171

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

The sellers CD and the combined final CD disclosed -0- in seller paid costs.  The Estimated sellers statement disclosed fees paid by the seller that are not on the Sellers or combined CD.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360172

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360172

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.65160% or Final Disclosure APR of 5.66500% is in excess of allowable threshold of APOR 3.28% + 1.5%, or 4.78000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360172

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.65160% or Final Disclosure APR of 5.66500% is in excess of allowable threshold of APOR 3.28% + 1.5%, or 4.78000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360172

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360172

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Closing Date was stated as [MM/DD/YYYY] and the borrower closed on [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360172

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $45,458.95 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360172

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $23.02 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

No Change of Circumstance for the addition of this fee

Reviewer Comment (2017-02-27): Lender provided $573.02 credit at closing for increase in Closing Costs above legal limit.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360172

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-27): Lender provided $573.02 credit at closing for increase in Closing Costs above legal limit.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360173

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360173

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.65080% or Final Disclosure APR of 5.67400% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360173

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $42,126.17 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360173

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360173

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.65080% or Final Disclosure APR of 5.67400% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360173

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360175

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360175

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64970% or Final Disclosure APR of 5.66000% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360175

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Field is blank. Closing Disclosure was signed on [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360175

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $13,137.47 were disclosed on the seller's CD.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360175

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64970% or Final Disclosure APR of 5.66000% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360175

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360176

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360176

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.70970% or Final Disclosure APR of 5.72400% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360176

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.70970% or Final Disclosure APR of 5.72400% is in excess of allowable threshold of APOR 3.23% + 1.5%, or 4.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360176

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360176

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $22,382.38 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360176

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360178

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.65200% or Final Disclosure APR of 5.66500% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360178

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.65200% or Final Disclosure APR of 5.66500% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360178

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360178

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Closing date reflected on Final CD is [MM/DD/YYYY]; however actual closing date is [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360178

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $9,650.30 were disclosed on the seller's CD.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360178

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360179

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360179

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360179

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $19,427.68 were disclosed on the seller's CD.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360179

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360180

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360180

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.77000% or Final Disclosure APR of 5.80500% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 5.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360180

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.77000% or Final Disclosure APR of 5.80500% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

Note rate is 5.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360180

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360180

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $35,357.00 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360180

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Lender's tracking worksheet indicates a CD was providsed on [MM/DD/YYYY]. This CD was not provided for review

Reviewer Comment (2017-03-09): Initial CD provided

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360180

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360181

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360181

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64640% or Final Disclosure APR of 5.68900% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360181

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account Statement Missing

RESPA (2010): Initial escrow account statement was not provided to the borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360181

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64640% or Final Disclosure APR of 5.68900% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360181

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Field is blank. Borrower signed loan documents on [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360181

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360182

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.73890% or Final Disclosure APR of 5.77500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360182

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

Unable to determine if Safe Harbor requirements are met due to missing information.

File is missing appraisal.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360182

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

File is missing appraisal.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360182

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360182

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.73890% or Final Disclosure APR of 5.77500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360182

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360182

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD shows closing date of 1[MM/DD/YYYY] vs actual consummation date of 12/8/16.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360182

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $34,798.54 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360182

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt not found in file.

Reviewer Comment (2017-03-09): received initial CD.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360182

Compliance

Loan Package Documentation

Application / Processing

Missing Document: Missing Lender's Initial 1003

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360182

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360182

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-22): Received copy of appraisal.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360182

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2017-03-22): Received copy of appraisal.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360182

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

Added [MM/DD/YYYY] upon receipt of esigned CD

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

Non QM

Non QM

No

C

B

201360182

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.73890% or Final Disclosure APR of 5.77500% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360183

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360183

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $26,623.44 were disclosed on the seller's CD.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360183

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360184

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.82870% or Final Disclosure APR of 5.87200% is in excess of allowable threshold of APOR 3.30% + 1.5%, or 4.80000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360184

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360184

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): [MM/DD/YYYY] Received copy of initial CD issued to borrower on [MM/DD/YYYY] and received on [MM/DD/YYYY], issue cleared.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360184

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.82870% or Final Disclosure APR of 5.87200% is in excess of allowable threshold of APOR 3.30% + 1.5%, or 4.80000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360184

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $71,105.47, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360184

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360187

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states loan cannot be assumed/

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360187

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Missing initial CD. E consent form shows CD was received electronically by borrower on [MM/DD/YYYY].

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360187

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $58,937.95 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $1,710.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360187

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360189

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360189

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.83080% or Final Disclosure APR of 5.86800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

Note rate is 5.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360189

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $19,961.95 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360189

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.83080% or Final Disclosure APR of 5.86800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 5.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360191

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360191

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

The notary date was 1[MM/DD/YYYY] and the closing date on the CD is 1[MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360191

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $133,573.09 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360191

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360191

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360192

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.86670% or Final Disclosure APR of 5.89700% is in excess of allowable threshold of APOR 3.32% + 1.5%, or 4.82000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360192

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation was not provided.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360192

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $33,526.56 were disclosed on the seller's CD.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360192

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.86670% or Final Disclosure APR of 5.89700% is in excess of allowable threshold of APOR 3.32% + 1.5%, or 4.82000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360192

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360193

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360193

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on 1[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360193

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $339,920.70 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360193

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-22): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-09): Final CD already reviewed in original submission package.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360194

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

False - The property is not located within a Flood Area according to the Department of Homeland Security FEMA review dated

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360194

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

The loan file did not contain a Valuation or a Secondary Valuation for review.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360194

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.84090% or Final Disclosure APR of 5.84700% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Loan.

The loan passed the High Cost Compliance test per the Compliance test located in the loan file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360194

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360194

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $59,176.95 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360194

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360194

Compliance

Property - Appraisal

General Appraisal Requirements

Due to lack of appraised value, compliance tests requiring an LTV were run off an assumed value of a contract sales price or original loan amount, whichever applies.

Reviewer Comment (2017-03-29): Seller provided the appraisal and compliance testing was completed.

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360194

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.84090% or Final Disclosure APR of 5.84700% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360194

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360194

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360194

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360194

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360194

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.84090% or Final Disclosure APR of 5.84700% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360194

Credit

Loan Package Documentation

Application / Processing

Valuation Error: APN Number not provided.

Valuation Type: Appraisal / Valuation Report Date: [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201360197

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360197

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Fee disclosed as $500 on the LE dated [MM/DD/YYYY], but disclosed as $600 on Final Closing Disclosure.

Reviewer Comment (2017-02-28): Lender provided $100.20 credit at closing for increase in Closing Costs above legal limit.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360197

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360197

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

The final CD is missing the closing date, [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360197

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $12,798.74 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360197

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.76090% or Final Disclosure APR of 5.76500% is in excess of allowable threshold of APOR 3.51% + 1.5%, or 5.01000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360197

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.76090% or Final Disclosure APR of 5.76500% is in excess of allowable threshold of APOR 3.51% + 1.5%, or 5.01000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360198

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360198

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.82570% or Final Disclosure APR of 5.85300% is in excess of allowable threshold of APOR 3.38% + 1.5%, or 4.88000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360198

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.82570% or Final Disclosure APR of 5.85300% is in excess of allowable threshold of APOR 3.38% + 1.5%, or 4.88000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360198

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller CD fees total $0.00 and closing CD seller's fees total $0.00, no attestation in file that the loan did not include any seller-paid fees.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360198

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360198

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing Date is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360200

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Missing Appraisal to confirm

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360200

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360200

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.78240% or Final Disclosure APR of 5.81200% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360200

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Missing Appraisal

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360200

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Missing Appraisal

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360200

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.78240% or Final Disclosure APR of 5.81200% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360200

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on 1[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360200

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure 1[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $25,077.78 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360200

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360200

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.78240% or Final Disclosure APR of 5.81200% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360201

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.73360% or Final Disclosure APR of 5.74000% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360201

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.73360% or Final Disclosure APR of 5.74000% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360201

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360201

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Final CD does not reflect any Seller paid fees.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360201

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360201

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360203

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360203

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.79430% or Final Disclosure APR of 5.81100% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360203

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Field is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360203

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $9,126.43 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360203

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.79430% or Final Disclosure APR of 5.81100% is in excess of allowable threshold of APOR 3.31% + 1.5%, or 4.81000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360203

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360204

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360204

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal was made "subject to" and Form 442 was not provided.

Valuation Type: Appraisal / Valuation Report Date:

Reviewer Comment (2017-03-15): Received copy of 442 Completion Cert.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.78170% or Final Disclosure APR of 5.79800% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

(Fed HPML Disclosure) Federal Higher-Priced Mortgage Loan (Right to Receive Cope of Appraisal)

TILA HPML Appraisal Rule (Dodd-Frank 2014):  Creditor did not provide "Right to Receive Copy" appraisal disclosure to consumer within three (3) business days of application.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

RESPA Servicing Disclosure:  Servicing Disclosure Statement Not Provided Within 3 Business Days of Application

RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Statement to applicant within three (3) business days of application.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.78170% or Final Disclosure APR of 5.79800% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $28,593.70, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360204

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360204

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.78170% or Final Disclosure APR of 5.79800% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360205

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Missing the origination appraisal.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360205

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360205

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $64,096.98 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360205

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Documentation indicates an initial CD was provided on [MM/DD/YYYY]. This CD was not provided for review.

Reviewer Comment (2017-03-22): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-09): CD provided already reviewed.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

Documentation indicates an initial LE was provided on [MM/DD/YYYY]. This LE was not provided for review.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

The SSPL was not provided for review.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $135.00 exceeds tolerance of $0.00 plus 10% or $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2017-02-28): This was cured at settlement.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360205

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status.

Missing the [MM/DD/YYYY] LE.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

RESPA Servicing Disclosure:  Servicing Disclosure Statement Not Provided Within 3 Business Days of Application

RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Statement to applicant within three (3) business days of application.

Missing the [MM/DD/YYYY] LE.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360205

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-15): Downgraded this exception from an EV3 to an EV2 based on the attestation from Sterling that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360206

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360206

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; Final CD states the loan cannot be assumed. Note contains assumability language.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360206

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360206

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $47,398.40, while closing CD seller's fees total $0.00.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360207

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360207

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.77890% or Final Disclosure APR of 5.80300% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360207

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $26,009.00 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360207

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360207

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.77890% or Final Disclosure APR of 5.80300% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360208

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final Closing Disclosure issued on [MM/DD/YYYY] reflects a closing date of [MM/DD/YYYY]. Consummation date is [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360208

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $76,493.06 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360208

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360208

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $172.00 exceeds tolerance of $150.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Cure of $22.00 reflected on final disclosure.

Reviewer Comment (2017-02-28): Cure of $22.00 reflected on final disclosure.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360208

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360208

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360209

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360209

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.73230% or Final Disclosure APR of 5.75600% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360209

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.73230% or Final Disclosure APR of 5.75600% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360209

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360209

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360209

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $26,212.13, while closing CD seller's fees total $5,236.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360210

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.72480% or Final Disclosure APR of 5.74300% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360210

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $85,325.00, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360210

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360210

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM Rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360210

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360210

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.72480% or Final Disclosure APR of 5.74300% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360212

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360212

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.72930% or Final Disclosure APR of 5.74200% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360212

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.72930% or Final Disclosure APR of 5.74200% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Loan.

Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360212

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360212

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $ $129,301.81, while closing CD seller's fees total $0.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360212

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-22): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-09): All CDs provided were already reviewed in original submission.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360213

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD staes teh loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360213

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

The final CD does not reflect the closing date, [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360213

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $142,514.00 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360213

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360213

Credit

Credit

Misc

Credit Exception:

The file does not contain documentation that a third party pays for the  mortgage with a monthly payment of . Debt was not included in the ratios.

Reviewer Comment (2017-03-20): Received evidence that other party is making payment.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360214

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360214

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.85860% or Final Disclosure APR of 5.87200% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360214

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.85860% or Final Disclosure APR of 5.87200% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360214

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360214

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

The closing date field is not completed on the early or final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360214

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $38,381.55, while closing CD seller's fees total $-0-.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360215

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360215

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing Date is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360215

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller CD fees total $0.00 and closing CD seller's fees total $0.00, no attestation in file that the loan did not include any seller-paid fees.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360215

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360218

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360218

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.75970% or Final Disclosure APR of 5.76600% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360218

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.75970% or Final Disclosure APR of 5.76600% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360218

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $11,483.20 were disclosed on the seller's CD.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360218

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360218

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM Rider identify loan can be assumed; final CD states loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360218

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Field is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360219

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360219

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.79740% or Final Disclosure APR of 5.80300% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

Note rate is 5.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360219

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and missing the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360219

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

File is missing the [MM/DD/YYYY] initial CD.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360219

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.79740% or Final Disclosure APR of 5.80300% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 5.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360221

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360221

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.73280% or Final Disclosure APR of 5.74500% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360221

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.73280% or Final Disclosure APR of 5.74500% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360221

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360221

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $53,228.05 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360221

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-22): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-09): CD provided already reviewed in original submission.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360221

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Origination Fee.  Fee Amount of $4,361.50 exceeds tolerance of $4,147.00.  Sufficient or excess cure was provided to the borrower at Closing. (7325)

Reviewer Comment (2017-02-28): Lender provided $214.50 credit to borrower at closing.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360221

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360222

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360222

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.78090% or Final Disclosure APR of 5.78400% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360222

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.78090% or Final Disclosure APR of 5.78400% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360222

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $36,683.72, while closing CD seller's fees total $-0-.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360222

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360222

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

The notary fee was disclosed on the LE as a Title - Notary fee.  The final CD did not reflect 'Title' terminology.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390292

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

49 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201390292

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.83860% or Final Disclosure APR of 6.83900% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201390292

Compliance

Compliance

State Compliance

North Carolina Rate Spread Threshold Test

North Carolina Rate Spread Home Loan: APR on subject loan of 6.83860% or Final Disclosure APR of 6.83900% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Rate Spread Home Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201390292

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

No evidence on file CD was sent electronically.  Assumed receipt date is [MM/DD/YYYY].

Reviewer Comment (2017-03-02): File contains evidence that a more recent disclosure that reflects accurate terms of loan has been received within timing requirements. Reviewer Comment (2017-02-17): Document provided does not show proof of receipt.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201390292

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Realtor commissions were not disclosed on Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390293

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.  Note:  Collateral Desk Review Fee disclosed on Final CD, but no review in images.

Guideline variance approved by lender at time of origination Significant excess monthly residual income of $1332.80 per month.  Required monthly residual income is $1900.00.

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201390293

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.22870% or Final Disclosure APR of 6.22900% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201390293

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID - Non Compliant: Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Sellers CD fees total $29,354.62 while closing CD sellers fees total $28.845.04.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390293

Credit

Credit

Misc

Credit Exception:

64.27% DTI exceeds guideline of 50%.  Lender exception in images for DTI of 58.810%.  Incorrect calculation of income by Lender.  .

Guideline variance approved by lender at time of origination Significant excess monthly residual income of $1332.80 per month.  Required monthly residual income is $1900.00.

Reviewer Comment (2017-02-17): Client elects to waive.

02/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201390293

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $495.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-16): Final Closing Disclosure reflects cure for $45.00.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201390294

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.69290% or Final Disclosure APR of 9.69600% is in excess of allowable threshold of APOR 4.22% + 1.5%, or 5.72000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201390294

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $95.00 exceeds tolerance of $65.00 plus 10% or $71.50.  Insufficient or no cure was provided to the borrower. (0)

Additional $30.00 was paid by the Seller.

Reviewer Comment (2017-03-02): Seller paid fee for recording of Seller's Trust.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201390294

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390294

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $ $10,628.54, while closing CD seller's fees total $10,312.20.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390294

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

60.51 months reserves > 3 months guideline minimum - borrowers have verified reserves of $78,910.97. Borrower on this Full documentation loan has a disposable income of $4,302.73.  Guidelines require $1,000.00; exceeds by $3,302.73. 42.66% DTI on this Full documentation loan < 50% guideline max - 7.34% below program guideline maximum

Reviewer Comment (2017-02-27): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201390295

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

The first two loan estimates used the with seller form. All subsequent LE's and CD's used the without seller form.

Reviewer Comment (2017-02-16): All subsequent LE's and CD's used the without seller form.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390295

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-02-17): Received evidence that borrower received disclosure within timing requirements.

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201390295

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-02-17): Received evidence that borrower received disclosure within timing requirements.

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201390295

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-02-23): Received evidence that borrower received disclosure within timing requirements.

02/23/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201390295

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.49550% or Final Disclosure APR of 8.49600% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201390295

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $8.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7579)

Fee was not on loan estimate

Reviewer Comment (2017-02-16): Lender provided $100.25 credit at closing for increase in Closing Costs above legal limit.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201390295

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee was not on loan estimate

Reviewer Comment (2017-02-16): Lender provided $100.25 credit at closing for increase in Closing Costs above legal limit.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201390295

Credit

Assets

Asset Documentation

Aged document: Asset Account is older than guidelines permit

Financial Institution:/ End Date: [MM/DD/YYYY] // Account Type: Savings / Account Number

Bank statement is stale dated.  Provide statement within 90 days of note date.

Reviewer Comment (2017-02-27): Received source of large deposit. Reviewer Comment (2017-02-20): Received acceptable bank statement.  However, there is a deposit of $79592.43 that must be sourced.  Statement states it's from IRA but no confirming documentation has been provided.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201390296

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

29.29% DTI on this Full documentation loan < 50% guideline max - 20.71% below program guideline maximum 87.72 months reserves > 9 months guideline minimum - borrowers have verified reserves of $127,843.39.

Reviewer Comment (2017-03-02): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201390296

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.18680% or Final Disclosure APR of 8.19900% is in excess of allowable threshold of APOR 4.22% + 1.5%, or 5.72000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201390296

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $9,699.84, while closing CD seller's fees total $2,539.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390296

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

Reviewer Comment (2017-03-02): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390296

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search.  Fee Amount of $250.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75178)

Reviewer Comment (2017-03-02): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390296

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Electronic Document Delivery Fee.  Fee Amount of $45.00 exceeds tolerance of $40.00.  Insufficent or no cure was provided to the borrower. (75188)

Fee is reflected in Section B but vendor is no on the SSPL.

Reviewer Comment (2017-03-02): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390296

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75197)

Fee is reflected in Section B but vendor is no on the SSPL.

Reviewer Comment (2017-03-02): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390296

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title-IL Predatory Lending Database Fee.  Fee Amount of $135.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7543)

Fee is reflected in Section B but vendor is no on the SSPL.

Reviewer Comment (2017-03-02): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390296

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee.  Fee Amount of $1,375.00 exceeds tolerance of $1,090.00.  Insufficent or no cure was provided to the borrower. (7561)

Fee is reflected in Section B but vendor is no on the SSPL.

Reviewer Comment (2017-03-02): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390296

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title fees are listed in Section B: Services Borrower Did Not Shop For, however, the borrower did not use the provider listed on the SPPL. These fees should have been in Section C: Services Borrower Did Shop For.

Reviewer Comment (2017-03-02): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390298

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Residual Income required $2,200.00; Verified is $6,555.93. Housing Payments verified at 42 months of on time payments. 80,211.62 reserves exceeds $35847 required. X793 representative FICO score > 680 guideline minimum

Reviewer Comment (2017-03-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201390298

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

CD reflects $596.86, calculates to be $596.04.  (46.97 x 12)

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390298

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390298

Credit

Credit

Misc

Credit Exception:

Lender Approved an Exception to use less than 25% equity in vacated property in order to use rental income.  Current equity using sales price would be 16.5% .  If we use the AVM Value quality would be at 18%

Residual Income required $2,200.00; Verified is $6,555.93. Housing Payments verified at 42 months of on time payments. 80,211.62 reserves exceeds $35847 required. X793 representative FICO score > 680 guideline minimum

Reviewer Comment (2017-02-17): Client elects to waive.

02/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201390298

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on  [MM/DD/YYYY] reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section. (Final/[MM/DD/YYYY])

Collateral Desktop Analysis Fee paid to Lender.  No evidence of invoice in file to verify it is a pass through fee.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390298

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for $150 Collateral Desktop Analysis Fee was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201390298

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee not disclosed on LE.

Reviewer Comment (2017-03-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201390299

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.76320% or Final Disclosure APR of 7.76300% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201390299

Compliance

Compliance

State Compliance

(State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided)

Maryland Higher-Priced Mortgage Loan:  Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201390299

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 7.76320% or Final Disclosure APR of 7.76300% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201390299

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390299

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $450.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75103)

Reviewer Comment (2017-02-17): Final CD reflects $610 Lender Credit for Tolerance Cure.

02/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201390299

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Fee collected but no report provided.

42% DTI on this full documentation loan < 50% guideline max - 8% below program guideline maximum

Reviewer Comment (2017-03-13): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201390300

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

47% < 50% max

Reviewer Comment (2017-02-17): Client elects to waive.

02/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201390300

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.05330% or Final Disclosure APR of 8.05300% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201390301

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.12560% or Final Disclosure APR of 7.12600% is in excess of allowable threshold of APOR 4.22% + 2.5%, or 6.72000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.00%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201390301

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201390301

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2017-02-16): This was cured at settlement.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

B

B

201390759

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this full documentation loan has a disposable income of $2,852.09 when required is $1,300. Excess of $1,552.09. 35.83% DTI on this full documentation loan < 43% guideline max - 7.17% below program guideline maximum. 43.24% LTV < 80% guideline max -  $169, 996.62 more equity than required by program guidelines.

Reviewer Comment (2017-02-17): Client elects to waive.

02/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201390759

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.48830% or Final Disclosure APR of 6.48800% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201390759

Credit

Credit

Misc

Credit Exception:

Cash out transaction without having owned the property for 6 months.

Borrower on this full documentation loan has a disposable income of $2,852.09 when required is $1,300. Excess of $1,552.09. 35.83% DTI on this full documentation loan < 43% guideline max - 7.17% below program guideline maximum. 43.24% LTV < 80% guideline max -  $169, 996.62 more equity than required by program guidelines.

Reviewer Comment (2017-02-17): Client elects to waive.

02/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201390760

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.46040% or Final Disclosure APR of 8.46000% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201390760

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Employment Fee.  Fee Amount of $65.90 exceeds tolerance of $37.00.  Sufficient or excess cure was provided to the borrower at Closing. (7571)

Reviewer Comment (2017-02-17): Lender gave borrower a $157.21 credit at closing.

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201390760

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

172 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-20): Client elects to waive.

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201390760

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $9,174.60 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $63,684.98.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392354

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

16 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201392354

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2017-02-20): Data was corrected on subsequent disclosures.

02/20/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201392354

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $70.72 exceeds tolerance of $20.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-02-20): Final CD reflects $4682.72 lender credit for tolerance cure.

02/20/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201392354

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-02-20): Final CD reflects $4682.72 lender credit for tolerance cure.

02/20/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201392354

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $7,866.00 exceeds tolerance of $3,236.00.  Insufficent or no cure was provided to the borrower. (8304)

Reviewer Comment (2017-02-20): Final CD reflects $4682.72 lender credit for tolerance cure.

02/20/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201392355

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-21): Cured at closing.

02/21/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

N/A

N/A

Yes

C

B

201392355

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

Guideline Issue: Number of properties financed exceeds amount allowed by guidelines.

Lender approved Exception.  Borrower has financed properties with , exceeds max of 5 properties.

Borrower on this Full Documentation loan  has a disposable income of $17,999.88 Housing consistency 76 months history of payments 75% LTV for program with 85% max

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201392355

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID Non-Compliant:  Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $12,046.00 while Closing CD seller fees total $13,039.00

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201392355

Credit

Assets

Asset Documentation

Assets Error: Usability  was not provided

Guidelines require verification that Borrower owns 100% of business, no evidence found in file to confirm 100% ownership.

Reviewer Comment (2017-03-02): Received evidence that borrower owns 100% of company.

03/02/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

C

A

C

A

C

A

C

A

C

A

N/A

N/A

No

C

B

201392361

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved.

28.59% DTI on this Full documentation loan < 50% guideline max - 21.41% below program guideline maximum Residual Income: $3,627.52 vs. Required Residual Income: $600.00. 54.50 months reserves > 6 months guideline minimum - borrowers have verified reserves of $61,717.67

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201392361

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

28.59% DTI on this Full documentation loan < 50% guideline max - 21.41% below program guideline maximum Residual Income: $3,627.52 vs. Required Residual Income: $600.00. 54.50 months reserves > 6 months guideline minimum - borrowers have verified reserves of $61,717.67

Reviewer Comment (2017-03-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201392361

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.95030% or Final Disclosure APR of 8.95000% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201392361

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395777

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

67 months reserves > 6 months guideline minimum

Reviewer Comment (2017-02-23): Client elects to waive.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201395777

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.86870% or Final Disclosure APR of 8.88000% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201395777

Compliance

Compliance

State Compliance

North Carolina Rate Spread Threshold Test

North Carolina Rate Spread Home Loan: APR on subject loan of 8.86870% or Final Disclosure APR of 8.88000% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Rate Spread Home Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201395777

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the 10% tolerance issues.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395777

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Discrepancy is due real estate commission paid to sellers agent not being disclosed on Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395777

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,089.10 exceeds tolerance of $725.00 plus 10% or $797.50.  Insufficient or no cure was provided to the borrower. (0)

Title - Administrative Fee ($50.00), Title - Settlement/Closing/Escrow Fee ($625.00), Title - Electronic Document Delivery Fee ($35.00) were added on LE issued on [MM/DD/YYYY] but no valid change of circumstance in the file.

Reviewer Comment (2017-03-03): Title Attorney Fee same as Title Settlement/Closing Fee.

03/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201395777

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $10.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7579)

Reviewer Comment (2017-02-22): Lender gave borrower $105 credit at closing.

02/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395777

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $370.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

Reviewer Comment (2017-02-23): Erroneous Reg ID 3060.  This fee was seller paid, and is customarily paid by Seller in the state of NC.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395777

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $95.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-02-22): Lender gave borrower $105 credit at closing.

02/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395778

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $91,174.73 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $68,931.25.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201395778

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $375.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7507)

Fee not disclosed on loan estimate

Reviewer Comment (2017-02-22): Lender provided $540.00 credit at closing for increase in Closing Costs above legal limit.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

B

B

201395778

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Management Company Fee.  Fee Amount of $125.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7510)

Fee not disclosed on loan estimate

Reviewer Comment (2017-02-22): Lender provided $540.00 credit at closing for increase in Closing Costs above legal limit.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

B

B

201395778

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $190.00 exceeds tolerance of $150.00.  Sufficient or excess cure was provided to the borrower at Closing. (75103)

Reviewer Comment (2017-02-22): Lender provided $540.00 credit at closing for increase in Closing Costs above legal limit.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

B

B

201395782

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Per Lender exception, additional 12 months reserves verified. Lender exception.  Borrower on this full documentation loan has a disposable income of $6,840.00.

Reviewer Comment (2017-03-02): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201395782

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-02-28): Received evidence that borrower received disclosure within timing requirements.

02/28/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201395782

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,723.80 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

Reviewer Comment (2017-02-22): Erroneous Reg ID 3060.  This fee was seller paid, and is customarily paid by Seller in the state of NV.

02/22/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201395782

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-22): Erroneous Reg ID 3060.  This fee was seller paid, and is customarily paid by Seller in the state of NV.

02/22/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201395782

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $26,559.35 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $25,640.35.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201395782

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Per Lender exception, additional 12 months reserves verified. Lender exception.  Borrower on this full documentation loan has a disposable income of $6,840.00.

Reviewer Comment (2017-02-23): Client elects to waive.

02/23/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201395782

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-23): All guideline violations have been addressed by client.

02/23/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201395782

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-23): All guideline violations have been addressed by client.

02/23/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201398778

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee was collected but no report provided.

30 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-07): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201398778

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.41770% or Final Disclosure APR of 9.41800% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201398778

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

TIEFF fee reflected in section B, should be in section C.  Provider used is not listed on SSPL.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201398780

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

36 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-07): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201398780

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.38200% or Final Disclosure APR of 8.38600% is in excess of allowable threshold of APOR 3.51% + 1.5%, or 5.01000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201398780

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $27,120.90 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $220,390.96.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201398780

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $449.00 exceeds tolerance of $377.00 plus 10% or $414.70.  Sufficient or excess cure was provided to the borrower at Closing. (0)

New fees added to closing disclosure

Reviewer Comment (2017-02-24): Lender provided $34.30 credit at closing for increase in Closing Costs above legal limit.

02/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201398781

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

19% DTI on this full documentation loan < 50% guideline max - 31% below program guideline maximum

Reviewer Comment (2017-03-08): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201398781

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.11290% or Final Disclosure APR of 7.11300% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201398781

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $ $16,284.00, while closing CD seller's fees total 16,175.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201398781

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $500.00 exceeds tolerance of $250.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Sufficient cure was provided to the borrower at Closing.

Reviewer Comment (2017-02-23): Lender provided $250.00 credit at closing for increase in Closing Costs above legal limit.

02/23/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201398782

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.21110% or Final Disclosure APR of 6.21100% is in excess of allowable threshold of APOR 3.55% + 1.5%, or 5.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201398782

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201398782

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-713.00. (9300)

Reviewer Comment (2017-03-07): Credit moved to correct section of post close CD (original on page 3 of final CD).

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201398782

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $26,576.20 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $6,033.44.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201398782

Credit

Credit

Credit Documentation

Missing Document: Verification of Rent (VOR) / Verification of Mortgage (VOM) not provided

Reviewer Comment (2017-03-07): Credit supplement reflects 0x30.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201398783

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this (Documentation Type) documentation loan has a disposable income of $3,317, more than minimum requirement of $1,800

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201398783

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.75480% or Final Disclosure APR of 8.75500% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201398783

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Initial LE used the with seller form. All subsequent LE's and CD's used the without seller form.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201398783

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender approved exception.

Borrower on this (Documentation Type) documentation loan has a disposable income of $3,317, more than minimum requirement of $1,800

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201398783

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201398783

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-458.00. (9300)

Reviewer Comment (2017-03-02): Received VCC regarding rate reduction and credit reflecting $0.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201398783

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $57.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-02-24): Lender provided $35.00 credit at closing for increase in Closing Costs above legal limit.

02/24/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201398784

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

696 > required 660.

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201398784

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.57450% or Final Disclosure APR of 8.57500% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201398784

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for $1803 reduction in Lender Credit was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201398784

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,803.00. (9300)

LE dated[MM/DD/YYYY] reflects $1803 Lender Credit (loan was locked) and Final CD reflects $0.00 Lender Credit.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.

Reviewer Comment (2017-03-03): Received corrected CD with lender credit reflected in the correct section.  Credit was supplied at closing verified through final settlement statement.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201398784

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $26,003.54.  Borrower's CD reflects $47,904.34.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201398784

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Summaries of Transactions data field is blank.  Calculating Cash to Close reflects $0.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201400699

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

200 months reserves > 12 months guideline minimum

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201400699

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $17,790.46 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $489.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201400699

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.21560% or Final Disclosure APR of 6.25900% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201400699

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-27): Lender provided $205.42 credit at closing for increase in Closing Costs above legal limit.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201440249

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-03-02): Received evidence that borrower received disclosure within timing requirements.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201440249

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440249

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on  [MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

REMOVE: Original application date to creditor was [MM/DD/YYYY] - Construction - Perm.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201440250

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower has $252 in excess residual income. DTI below allowed 50% Verified satisfactory rental payment history for the most recent 24 months

Reviewer Comment (2017-02-28): Client elects to waive.

02/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440250

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201440250

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-04-12): Exception regarded to EV2-B, based on subsequent LE provided to the consumer at least 4 days prior to consummation. Reviewer Comment (2017-03-09): Due to Washington's Birthday federal holiday, the timing requirements have not been met. Reviewer Comment (2017-03-06): Per Compliance, disclosure needs to be received at least 4 days PRIOR to closing, or on the 15th. Seller Comment (2017-03-06): Lender states that borrower received LE exactly 4 days from closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440250

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-02): Received evidence that borrower received disclosure within timing requirements.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201440250

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-02): Received evidence that borrower received disclosure within timing requirements.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201440250

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

$60.02 x 8 days = $480.16. CD shows $465.44.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440250

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $20,874.03 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $22,154.03.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440250

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.45560% or Final Disclosure APR of 7.45600% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201440250

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Borrower has $252 in excess residual income. DTI below allowed 50% Verified satisfactory rental payment history for the most recent 24 months

Reviewer Comment (2017-02-28): Client elects to waive.

02/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440251

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $36.35 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-02-27): Lender cured on final CD with $36.35 tolerance cure.

02/27/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201440251

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440252

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

45% DTI on this full documentation loan < 50% guideline max - 5% below program guideline maximum

Reviewer Comment (2017-02-28): Client elects to waive.

02/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440252

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.40860% or Final Disclosure APR of 7.40900% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201440252

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440252

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $575.00 exceeds tolerance of $475.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-28): Cured at closing.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201440254

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.50500% or Final Disclosure APR of 6.50500% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201440254

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

25 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-01): Client elects to waive.

03/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440254

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $279.50 exceeds tolerance of $210.00 plus 10% or $231.00.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-03-01): Cured at closing.

03/01/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201440254

Credit

Credit

Credit Calculation / Analysis

Guideline Issue:  Insufficient tradelines per credit guidelines

0  trade lines < 3 minimum requirement per guidelines, lender used Non-Traditional Credit trade lines which is not allowed on the approved loan program.

25 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-06): Client elects to waive.

03/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440254

Credit

Credit

Credit Eligibility

Guideline Issue:  Foreclosure timeline outside of credit guidelines

Previous foreclosure  yrs prior to Close vs 4 rs minimum requirement per guidelines.  Per RICOA in file all foreclosed properties were included in BK 7 in  and lender used BK discharge date for foreclosure date; however, per the BK 7 documents in the file the property  was re-affirmed by the borrowers and per the  in file, the foreclosure of the property took place on .

Reviewer Comment (2017-03-03): Per Guides:  If a borrower with a Bankruptcy Chapter 7 has a foreclosure or short sale after the date of discharge, such foreclosure, short sale or mortgage loan charge off should be disregarded for purposes of determining the accrual date.

03/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201440255

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this Full documentation loan has a disposable income of $10,000.66; Guidelines require $1,650.00. 19.65 months reserves > 3 months guideline minimum - borrowers have verified reserves of $39,372.22.

Reviewer Comment (2017-02-28): Client elects to waive.

02/28/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440255

Credit

Credit

Credit Eligibility

Public Record Issue:

Previous DIL  < 2 yrs prior to Application vs 2 yrs minimum requirement per guidelines.

Borrower on this Full documentation loan has a disposable income of $10,000.66; Guidelines require $1,650.00. 19.65 months reserves > 3 months guideline minimum - borrowers have verified reserves of $39,372.22.

Reviewer Comment (2017-02-28): Client elects to waive.

02/28/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201440255

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Loan Estimate dated [MM/DD/YYYY] shows Closing Costs To/From and Calculating Cash to Close table is Without Seller

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440255

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID Final Closing Disclosure[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440255

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

Sufficient or excess cure was provided to the borrower at Closing.

Reviewer Comment (2017-02-28): Cured at closing.

02/28/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201440256

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

26% DTI on this full documentation loan < 50% guideline max - 24% below program guideline maximum

Reviewer Comment (2017-02-28): Client elects to waive.

02/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440256

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.95580% or Final Disclosure APR of 7.95600% is in excess of allowable threshold of APOR 4.23% + 1.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201440256

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201440256

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440256

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,139.00 exceeds tolerance of $1,900.00 plus 10% or $2,090.00.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-02-28): Cured at closing.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201440256

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $85.50 exceeds tolerance of $60.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-02-28): Cured at closing.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201440257

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34.96% DTI on this Full documentation loan < 50% guideline max - 15.04% below program guideline maximum 17.55 months reserves > 6 months reserves - 11.55 months above program guideline minimum

Reviewer Comment (2017-03-01): Client elects to waive.

03/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201440257

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $256.00 exceeds tolerance of $175.00 plus 10% or $192.50.  Insufficient or no cure was provided to the borrower. (0)

Erroneous Reg ID 3061. $169 of this fee was seller paid, and is customarily paid by Seller in the state of NV.

Reviewer Comment (2017-03-01): Borrower paid $62.00 towards recording Deed and Mortgage. Seller paid the remaining $169.00 recording fees and is typical for Nevada.

03/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201440257

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $625.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee disclosed as $500 on the LE dated [MM/DD/YYYY] but disclosed as $625 on Final Closing Disclosure. Sufficient cure of $125 provided on the final CD.

Reviewer Comment (2017-03-01): Lender provided $125.00 credit at closing for increase in Closing Costs above legal limit.

03/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201440257

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 3061. $169 of this fee was seller paid, and is customarily paid by Seller in the state of NV.

Reviewer Comment (2017-03-01): Lender provided $125.00 credit at closing for increase in Closing Costs above legal limit and seller paid the excess recording fees.

03/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440257

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $3,195.62, while closing CD seller's fees total $3,278.12.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440257

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Field is blank and should be $0.00 (numeric).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201440257

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.47720% or Final Disclosure APR of 7.47700% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201483424

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

43 months reserves > 9 months guideline minimum

Reviewer Comment (2017-03-01): Client elects to waive.

03/01/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201483424

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.11490% or Final Disclosure APR of 6.11500% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201483424

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Verified

Reviewer Comment (2017-03-06): Received evidence that borrower received disclosure within timing requirements.

03/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201483424

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Verified

Reviewer Comment (2017-03-06): Received evidence that borrower received disclosure within timing requirements.

03/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201483424

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Verified

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201483425

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

Residual income of $3,305.75 exceeds required of $2,750 Reserves of 51 months exceeds required of 6 months LTV of 32% is well below maximum allowed of 80%

Reviewer Comment (2017-03-01): Client elects to waive.

03/01/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201483425

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.96320% or Final Disclosure APR of 7.00000% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-01): All guideline violations have been addressed by client.

03/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201483425

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-03-01): All guideline violations have been addressed by client.

03/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201483425

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-01): All guideline violations have been addressed by client.

03/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201483425

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-01): All guideline violations have been addressed by client.

03/01/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201483425

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.96320% or Final Disclosure APR of 7.00000% is in excess of allowable threshold of APOR 3.61% + 1.5%, or 5.11000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

Non QM

Non QM

No

C

B

201483426

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.92590% or Final Disclosure APR of 6.92700% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.0%

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201483426

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $ $41,798.63, while closing CD seller's fees total $12,624.63.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201483428

Compliance

Compliance

Federal Compliance

Flood Insurance Escrow - Flood not Escrowed for Property in Flood Zone

Loan originated post December 2015, the subject property  is in a flood zone, flood insurance is not escrowed.

Reviewer Comment (2017-03-29): Received evidence that flood insurance is included in HOA.

03/29/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Non QM

No

C

B

201483428

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-07): Designation switched to Non-QM

03/07/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201483428

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Reviewer Comment (2017-03-07): Designation switched to Non-QM

03/07/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201483428

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

Residual income of $3,213.80 is above the required $1,000 LTV of 70% is below the maximum of 85% which includes 5% reduction for non-warrantable condo Level 2/3 Reserves of 14 months versus required of 6 months

Reviewer Comment (2017-03-01): Client elects to waive.

03/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201483428

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-01): All guideline violations have been addressed by client.

03/01/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201483428

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual income of $3,213.80 is above the required $1,000 LTV of 70% is below the maximum of 85% which includes 5% reduction for non-warrantable condo Level 2/3 Reserves of 14 months versus required of 6 months

Reviewer Comment (2017-03-01): Client elects to waive.

03/01/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201483428

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-03-07): Designation switched to Non-QM

03/07/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201483430

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

27% DTI on this full documentation loan < 50% guideline max - 23% below program guideline maximum

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201483430

Compliance

Compliance

State Compliance

(State HPML) Connecticut Non-Prime Home Loan (APR Exceeds Non-Prime Threshold)

Connecticut Non-Prime Home Loan: APR on subject loan of 6.75750% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201483430

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-03-02): Lender cured on final CD with $2 tolerance cure.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201483430

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201483430

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.83260% or Final Disclosure APR of 6.83300% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201483430

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Reviewer Comment (2017-03-07): Add back of POC amount for insurance (evidenced by bank statement) covers amount needed for reserves.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201483431

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

255 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201483431

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $124.74 exceeds tolerance of $60.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-03-02): Cured at closing.

03/02/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201485417

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

6 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201485417

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201485417

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.10860% or Final Disclosure APR of 6.10900% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201485418

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.97140% or Final Disclosure APR of 6.97100% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201485418

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller did not pay any fees per final CD and seller's CD

Reviewer Comment (2017-03-07): Seller did not pay any fees per final CD and seller's CD

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201485418

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

6 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201485418

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $4,246.29 exceeds tolerance of $4,245.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-03-02): Cured at closing.

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201489292

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Verified and documented residual income in excess of $1000.00 minimum requirement; Verified $7,573.59. 82.63 months reserves > 6 months guideline minimum - borrowers have verified reserves of $86,609.76. Guideline variance approved by lender at time of origination. LTV of 75%; program allows for maximum 90% LTV

Reviewer Comment (2017-03-03): Client elects to waive.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201489292

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.61490% or Final Disclosure APR of 7.61800% is in excess of allowable threshold of APOR 4.23% + 1.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201489292

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

Calculated finance charges are $162,419.11.  TIL/TRID finance charges are $162,179.11; Finance charge variance is $-240.00.  Lender did not include the $350 Condo Questionnaire fee in the finance charge.

Reviewer Comment (2017-03-10): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201489292

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $ $9,380.00, while closing CD seller's fees total $0. Corrected CD provided-Seller fees total $10,430.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201489292

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender approved exception for Non-Warrantable Condo Level 3 requirement of 700 FICO.

Verified and documented residual income in excess of $1000.00 minimum requirement; Verified $7,573.59. 82.63 months reserves > 6 months guideline minimum - borrowers have verified reserves of $86,609.76. Guideline variance approved by lender at time of origination. LTV of 75%; program allows for maximum 90% LTV

Reviewer Comment (2017-03-03): Client elects to waive.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201489292

Credit

Credit

Credit Documentation

Credit Report Error: Housing history rating was not provided.

Occupying Borrower lived rent free with family, per guidelines a 12 month housing history is required, only non-occupant Co-Borrower has housing history.  Lender approved exception.

Verified and documented residual income in excess of $1000.00 minimum requirement; Verified $7,573.59. 82.63 months reserves > 6 months guideline minimum - borrowers have verified reserves of $86,609.76. Guideline variance approved by lender at time of origination. LTV of 75%; program allows for maximum 90% LTV

Reviewer Comment (2017-03-03): Client elects to waive.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201489294

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved Exception to DTI:  Non-Warrantable Condo- Max DTI 43%.

Required residual income $1,000 versus actual $3,072.60 Reserves of 29 months > 12 months required

Reviewer Comment (2017-03-03): Client elects to waive.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201489294

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-03): All guideline violations have been addressed by client.

03/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201489294

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-03): All guideline violations have been addressed by client.

03/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201489294

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201489296

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.10880% or Final Disclosure APR of 7.10900% is in excess of allowable threshold of APOR 3.55% + 1.5%, or 5.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201489296

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201489297

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

108 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-14): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201489297

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201489297

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.10590% or Final Disclosure APR of 6.10600% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201489299

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.04710% or Final Disclosure APR of 6.04700% is in excess of allowable threshold of APOR 4.36% + 1.5%, or 5.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201489299

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201489299

Credit

Loan Package Documentation

Closing / Title

Security Instrument is not signed by borrower(s).

Mortgage is not signed by Notary

Reviewer Comment (2017-03-08): Received copy of entire Mortgage, including signature pages.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201489299

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Missing complete copy of Deed including signature pages.

Reviewer Comment (2017-03-08): Received copy of entire Mortgage, including signature pages.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201489300

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

29% DTI on this Premier Access loan < 43% guideline max - 14% below program guideline maximum Borrower on this (Documentation Type) documentation loan has a disposable income of $7,700, more than required amount of $1,300

Reviewer Comment (2017-03-14): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201489300

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.32650% or Final Disclosure APR of 6.32700% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201489300

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects 5351.98.  Borrower's CD reflects $5103.15.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201489300

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender approved.

29% DTI on this Premier Access loan < 43% guideline max - 14% below program guideline maximum Borrower on this (Documentation Type) documentation loan has a disposable income of $7,700, more than required amount of $1,300

Reviewer Comment (2017-03-07): Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201489300

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $2,016.92 exceeds tolerance of $2,016.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-03-07): Cured at closing.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201489301

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.49860% or Final Disclosure APR of 7.55500% is in excess of allowable threshold of APOR 4.22% + 2.5%, or 6.72000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201489301

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201489301

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure  [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller paid fees were not disclosed on Post Close CD.

Reviewer Comment (2017-03-08): Data correct on subsequent CDs (SFIG).

03/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201491262

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201491262

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-03-06): This was cured at settlement.

03/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201491262

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual Income; $1000 required; actual $2993.88. Cash Reserves; 6 months required; 23 months available.

Reviewer Comment (2017-03-07): Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201491262

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

52.26083% DTI exceeds guideline maximum of 50.0000%. Lender approved exception for 52.15% DTI.

Residual Income; $1000 required; actual $2993.88. Cash Reserves; 6 months required; 23 months available.

Reviewer Comment (2017-03-07): Client elect to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201491262

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.07770% or Final Disclosure APR of 7.07800% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Non-Compliant Higher Priced Mortgage Loan.

Note rate is 7.25%. DTI is 52.78616%

Reviewer Comment (2017-03-07): All guideline violations have been addressed by client.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201491262

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Note rate is 7.25%. DTI is 52.78616%

Reviewer Comment (2017-03-07): All guideline violations have been addressed by client.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201491262

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-07): All guideline violations have been addressed by client.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201491262

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-07): All guideline violations have been addressed by client.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201491262

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.07770% or Final Disclosure APR of 7.07800% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201491265

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-08): Client elects to waive.

03/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201491265

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201491265

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on[MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201491265

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201491265

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201491265

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.25880% or Final Disclosure APR of 7.25900% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201491266

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

13 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-14): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201491266

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.95900% or Final Disclosure APR of 7.95900% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201491266

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The file is missing a copy of the Seller's CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201491268

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.12160% or Final Disclosure APR of 7.12200% is in excess of allowable threshold of APOR 4.23% + 1.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201491268

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201491268

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $252, calculates to be $1043.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201491268

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,197.00. (9300)

LE dated [MM/DD/YYYY] reflects $1197 Lender Credit (loan was locked) and Final CD reflects $154 Lender paid fees.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.  Note:  COC dated[MM/DD/YYYY] reflects increase in rate from 7.0 to 7.75, however no reason is given for the increase.  Lender Credits on LE dated[MM/DD/YYYY] are $0.00.

Reviewer Comment (2017-03-17): Received detailed CoC for credit reduction.  File moved to Tier 3 on 2/13, then to Tier 2 on 2/23.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201491269

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

770 representative FICO score > 660 guideline minimum - 110 points above guideline minimum

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201491269

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.83930% or Final Disclosure APR of 5.83900% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201491272

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-03-08): Lender cured exception by refunding $260.00 to borrower at closing.

03/08/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

N/A

N/A

Yes

A

A

201491272

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $370.50 exceeds tolerance of $356.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-03-08): Lender cured exception by refunding $260.00 to borrower at closing.

03/08/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

N/A

N/A

Yes

A

A

201491273

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

42% DTI on this full documentation loan < 50% guideline max - 8% below program guideline maximum

Reviewer Comment (2017-03-08): Client elects to waive.

03/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201540250

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Low LTV Residual income of $1,049 Housing payment increase of 24.49%

Reviewer Comment (2017-03-09): Client elects to waive.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201540250

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.80790% or Final Disclosure APR of 6.80800% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-09): All guideline violations have been addressed by client.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201540250

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-03-09): All guideline violations have been addressed by client.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201540250

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-09): All guideline violations have been addressed by client.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201540250

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-09): All guideline violations have been addressed by client.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201540250

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201540250

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201540250

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

Low LTV Residual income of $1,049 Housing payment increase of 24.49%

Reviewer Comment (2017-03-09): Client elects to waive.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201540250

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-03-09): Lender cured on the final CD with $2 tolerance cure.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201540250

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.80790% or Final Disclosure APR of 6.80800% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201540251

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Co-borrower bonus and commission income not included in qualifying income due to lack of 2 year employment history.  Co-borrower began new employment 7/2015.  In 2016, received $5,301 in bonus and commission income. Residual income actual of $3,666 is higher than requirement of $2,700.  In addition, borrowers' have demonstrated and verified consistent on time housing payment history at current location for 36 months history when program required 24 months.

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201540251

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender Approved Excepiton

Co-borrower bonus and commission income not included in qualifying income due to lack of 2 year employment history.  Co-borrower began new employment 7/2015.  In 2016, received $5,301 in bonus and commission income. Residual income actual of $3,666 is higher than requirement of $2,700.  In addition, borrowers' have demonstrated and verified consistent on time housing payment history at current location for 36 months history when program required 24 months.

Reviewer Comment (2017-03-09): Client elects to waive.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201540251

Credit

Credit

Misc

Credit Exception:

Required equity of 25% in current residence being converted to rental is not met based on the appraisal in file and the current mortgage balance.  Lender approved exception.

Co-borrower bonus and commission income not included in qualifying income due to lack of 2 year employment history.  Co-borrower began new employment 7/2015.  In 2016, received $5,301 in bonus and commission income. Residual income actual of $3,666 is higher than requirement of $2,700.  In addition, borrowers' have demonstrated and verified consistent on time housing payment history at current location for 36 months history when program required 24 months.

Reviewer Comment (2017-03-09): Client elects to waive.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201540251

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.30840% or Final Disclosure APR of 7.30800% is in excess of allowable threshold of APOR 4.19% + 1.5%, or 5.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201540251

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201540251

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $855.00 exceeds tolerance of $595.00.  Insufficent or no cure was provided to the borrower. (73196)

Reviewer Comment (2017-03-16): Received VCC for increase in fee.

03/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201540251

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201540252

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

The file contained a Note for a different property and borrower versus the subject Note.

Reviewer Comment (2017-03-13): Received copy of executed Note.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

D

A

D

A

D

A

D

A

D

A

Higher Priced QM

Higher Priced QM

No

D

B

201540252

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

37 months reserves > 9 months guideline minimum

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.   Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

D

B

201540252

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.48700% or Final Disclosure APR of 6.48700% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

D

B

201540252

Compliance

Compliance

State Compliance

(State HPML) Minnesota Subprime (APR Exceeds Subprime Threshold)

Minnesota Subprime Loan: APR on subject loan of 6.48700% or Final Disclosure APR of 6.48700% is in excess of allowable threshold of USTreasury 3.0900% + 3%, or 6.09000%.  Compliant Subprime Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

D

B

201540252

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $645.00 exceeds tolerance of $475.00.  Insufficent or no cure was provided to the borrower. (7506)

Cure provided on Closing Disclosure

Reviewer Comment (2017-03-09): Lender cured on final CD with $170 tolerance cure.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201543147

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

18 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201543147

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.97480% or Final Disclosure APR of 6.97500% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201543147

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201543148

Compliance

Compliance

Federal Compliance

TRID non-compliant:  There is a partially completed TRID disclosure in file, which is insufficient to complete testing.

Pg 604, 609, 614 & 619 contain an incomplete closing disclosure.

Reviewer Comment (2017-03-14): Received attestation that disclosure was produced by title and never presented to borrower.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201543148

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Total Closing Costs did not exceed the legal limit

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201543148

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201543148

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $140.00 exceeds tolerance of $120.00 plus 10% or $132.00.  Insufficient or no cure was provided to the borrower. (0)

Unable to determine if seller paid portion is traditionally a buyer paid fee or not.

Reviewer Comment (2017-03-16): Received evidence that fee is POA recording fee responsible from the seller.

03/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201543148

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this full documentation loan has a disposable income of $3,600 when only $1,950 is required. 3 months reserves required when borrower has 30 months.

Reviewer Comment (2017-03-10): Client elects to waive.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543148

Credit

Credit

Credit Eligibility

Guideline Issue: Bankruptcy timeline outside of credit guidelines

CH 7 BK discharged only  yrs prior to the application date  vs 4 yrs minimum requirement per guidelines.  Lender approved exception.

Borrower on this full documentation loan has a disposable income of $3,600 when only $1,950 is required. 3 months reserves required when borrower has 30 months.

Reviewer Comment (2017-03-10): Client elects to waive.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543149

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Residual income: Minimum guideline requirements $3,200; Actual amount $4,400, exceeds by $1,200. Housing payment history: Product requirements: 0x30x12; Acutual 0x30 for 24 months.

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543149

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-17): Cured Data correct on subsequent CDs (SFIG).

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201543149

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.96660% or Final Disclosure APR of 6.96700% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201543149

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender approved exception

Residual income: Minimum guideline requirements $3,200; Actual amount $4,400, exceeds by $1,200. Housing payment history: Product requirements: 0x30x12; Acutual 0x30 for 24 months.

Reviewer Comment (2017-03-10): Client elects to waive.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543151

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

15 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-10): Client elects to waive.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543151

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.42580% or Final Disclosure APR of 7.42500% is in excess of allowable threshold of APOR 4.23% + 1.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201543151

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201543151

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75103)

Change of Circumstance provided for this fee dated[MM/DD/YYYY] however revised Loan Estimate dated [MM/DD/YYYY] - over the three day maximum requirement

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201543155

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

749 representative FICO score > 660 guideline minimum - 89 points above guideline minimum 238 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-15): Client elects to waive.

03/15/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Safe Harbor QM

No

C

B

201543155

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Safe Harbor QM.

Per deal notes, follow pre loaded designation.

Reviewer Comment (2017-03-17): Designation switched to Safe Harbor QM

03/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201543155

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM matches the Due Diligence Loan Designation of Safe Harbor QM.

Designation switched to Safe Harbor QM

Reviewer Comment (2017-03-17): Designation switched to Safe Harbor QM

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201543157

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

719 representative FICO score > 620 guideline minimum - 99 points above guideline minimum

Reviewer Comment (2017-03-13): Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201543157

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.20960% or Final Disclosure APR of 7.21000% is in excess of allowable threshold of APOR 4.19% + 1.5%, or 5.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201543157

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201543157

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,038.00. (9300)

Lender credit of $950 on final CD is less than the most recently disclosed lender credit of $1,038

Reviewer Comment (2017-03-17): Data correct on subsequent CDs (SFIG).  Total credit was on final CD.  Corrected CD moved fees to the correct section on page 2.  Credit is sufficient. Reviewer Comment (2017-03-16): Received updated CD, however amount of $950 does not meet exception amount referenced of $1038.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201543157

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201543157

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $70.00 exceeds tolerance of $65.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-03-13): Lender cured on final CD with $5 tolerance cure.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201564585

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

33 months reserves > 3 months guideline minimum 35.51% DTI on this full documentation loan < 50% guideline max - 14.49% below program guideline maximum Borrower on this  full documentation loan has a disposable income of $4,916.

Reviewer Comment (2017-03-21): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201564585

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.57410% or Final Disclosure APR of 6.57400% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as designated.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201564585

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The sellers CD has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201564586

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

14 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-14): Client elects to waive.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201564586

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.04340% or Final Disclosure APR of 8.04300% is in excess of allowable threshold of APOR 4.19% + 1.5%, or 5.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201564586

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-03-13): Lender cured on final CD with a $40.22 tolerance cure which included the $2 for the tax service fee.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201564586

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $133.22 exceeds tolerance of $95.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-03-13): Lender cured on final CD with $40.22 tolerance cure which included the $38.22 for the credit report.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201564589

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

24.88% DTI on this full documentation loan < 50% guideline max - 25.12% below program guideline maximum 42.73 months reserves > 3 months guideline minimum Borrower on this full documentation loan has a disposable income of $6,060.

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201564589

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.17090% or Final Disclosure APR of 6.17100% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

The is higher priced as designated.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201564589

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The sellers CD has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201564590

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

36.86% LTV < 80% guideline max 780 representative FICO score > 660 guideline minimum 10.84 months reserves > 3  months guideline minimum

Reviewer Comment (2017-03-21): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201564590

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

DTI > 43%  - Lender's DTI 46.72%.

Reviewer Comment (2017-03-17): Recalculated DTI reflects no violation.

03/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201564590

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Reviewer Comment (2017-03-17): Recalculated DTI reflects no violation.

03/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201564590

Credit

Credit

Misc

Credit Exception:

Lender Approved Exception for property being listed in the last 6 months.  Off market as of.

36.86% LTV < 80% guideline max 780 representative FICO score > 660 guideline minimum 10.84 months reserves > 3  months guideline minimum

Reviewer Comment (2017-03-15): Client elects to waive.

03/15/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201564590

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

TILA-RESPA Integrated Disclosure: Settlement Service Provider List did not provide at least one available provider for each settlement service borrower is entitled to shop for or inform borrower they may choose different provider from list.

Settlement Service Provider List in file is not TRID compliant (references GFE).

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201564590

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Notary fees reflected in section B, should be in section C.  Provider used is not listed on SSPL.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201590297

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Borrower on this full documentation loan has a disposable income of $5,002. 46.113% DTI on this full documentation loan < 50% guideline max - 3.887% below program guideline maximum 693 FICO score, exceeds required minimum of 680 by 13 points.

Reviewer Comment (2017-03-16): Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201590297

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The sellers CD has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201590297

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.95760% or Final Disclosure APR of 6.95800% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Non-Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

Reviewer Comment (2017-03-17): Exception reset as HPML Compliant.

03/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201590297

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.95760% or Final Disclosure APR of 6.95800% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201590300

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

21 months reserves > 9 months guideline minimum

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201590300

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.89480% or Final Disclosure APR of 7.89500% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201590300

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $23,423.40 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $28,325.35.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201590303

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

709 representative FICO score > 660 guideline minimum - 49 points above guideline minimum Borrower on this full documentation loan has a disposable income of $9,612.

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201590303

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.06460% or Final Disclosure APR of 6.06500% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201590303

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

The note, security instrument and final CD disclosed a closing date of [MM/DD/YYYY].  Consummation did not take place until [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201590303

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $114,986.73 while closing CD seller's fees total $8,690.84.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201590303

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.06460% or Final Disclosure APR of 6.06500% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201590303

Credit

Loan Package Documentation

Closing / Title

Title: Evidence of title is missing

Title commitment has not been provided in the loan documents.

Reviewer Comment (2017-03-21): Received copy of Title.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201600747

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

297 months reserves > 9 months guideline minimum

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Safe Harbor QM

No

C

B

201600747

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Safe Harbor QM.

Reviewer Comment (2017-03-21): Designation switched to Safe Harbor QM

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Safe Harbor QM

Yes

C

B

201600747

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on  [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 3062.  No tolerance violation of transfer taxes or recording fees due to the fees were seller paid and customarily paid by the Seller in the state of IL.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201600747

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The file is missing a copy of the Seller's CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201600747

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Safe Harbor QM matches the Due Diligence Loan Designation of Safe Harbor QM.

Designation switched to Safe Harbor QM

Reviewer Comment (2017-03-21): Designation switched to Safe Harbor QM

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Safe Harbor QM

Yes

C

B

201600748

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34.95% DTI on Full documentation loan < 50.00% guideline max - 15.00% below program guideline maximum 813 representative FICO score > 680 guideline minimum - 133 points above guideline minimum

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201600748

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.49650% or Final Disclosure APR of 6.51700% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201600748

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Lender cured exception by re-disclosing CD on [REDACTED] listing closing date as [REDACTED] and disbursement date as [REDACTED].

03/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201600749

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

708 representative FICO score > 660 guideline minimum - 48 points above guideline minimum 15.89 months reserves > 6 months guideline minimum - borrowers have verified reserves of $22,405.64.

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201600749

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-17): All guideline violations have been addressed by client.

03/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201600749

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-17): All guideline violations have been addressed by client.

03/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201618112

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Initial Loan Estimate disclosure was issued on the "Without Seller" form, and re-disclosed Loan Estimates, initial and final Closing Disclosures were issued on the "With Seller" form.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618112

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this full documentation loan has a disposable income of $5719.97 76 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-20): Client elects to waive.

03/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201618112

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $136.31 exceeds tolerance of $100.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Fee disclosed as $100 on LE dated [MM/DD/YYYY], but disclosed as $136.31 on Final Closing Disclosure. Sufficient cure provided on final CD.

Reviewer Comment (2017-03-20): Lender provided $136.31 credit at closing for increase in Closing Costs above legal limit.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201618112

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $8.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7579)

Fee was not disclosed on Loan Estimate. Sufficient cure provided on final CD.

Reviewer Comment (2017-03-20): Lender provided $136.31 credit at closing for increase in Closing Costs above legal limit.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201618112

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee was not disclosed on Loan Estimate. Sufficient cure provided on final CD.

Reviewer Comment (2017-03-20): Lender provided $136.31 credit at closing for increase in Closing Costs above legal limit.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201618112

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception in file.

Borrower on this full documentation loan has a disposable income of $5719.97 76 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-20): Client elects to waive.

03/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201618112

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.45690% or Final Disclosure APR of 7.45700% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

200900966

Compliance

Compliance

Federal Compliance

(Fed HPML) Federal Higher-Priced Mortgage Loan (Stated APR Exceeds HPML Threshold)

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.43650% or Final Disclosure APR of 7.43700% is in excess of allowable threshold of APOR 3.52% + 2.5%, or 6.02000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2016-09-13): Lender cured on re-disclosed LE dated[MM/DD/YYYY] and subsequent LE's and CD's having the same table usage.

09/13/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-10-17): Received evidence that disclosure was received within timing requirements.

10/17/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-09-30): Received copy of refund check, LOE, corrected CD, and proof of delivery.

09/30/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-10-17): Received evidence that disclosure was received within timing requirements.

10/17/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID - Fee Tolerance without Cure

TILA-RESPA Integrated Disclosure: Tolerance violation without evidence of sufficient cure provided.

Reviewer Comment (2016-09-30): Received copy of refund check, LOE, corrected CD, and proof of delivery.

09/30/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID -  Zero Percent Fee Tolerance

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $3,080.00 exceeds tolerance of $2,970.00. (8304)

Reviewer Comment (2016-09-30): Received copy of refund check, LOE, corrected CD, and proof of delivery.

09/30/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2016-09-27): Seller provided evidence that the borrower received the LE at least 4 business days prior to closing.

09/27/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

BW

200900966

Credit

Credit

Misc

Credit Exception:

Missing guideline required Desk Review.

Required $3700 residual income- Actual $4877.99. Additional $1,177.69 available. Borrowers previous 18 months mortgage payments are on time.

Reviewer Comment (2016-09-21): Client elected to waive.

09/21/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

BW

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title agent listed on SSPL and title fees incorrectly reflected in section C versus B.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

BW

200900966

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

BW

200900966

Property

Property - Appraisal

Appraisal Reconciliation

Value variance greater than 10% between origination appraisal and subsequent product

BPO has a value of $550k, -26.667% variance from original appraised value, $750k.

Reviewer Comment (2017-04-07): A Field review was received supporting the original Appraisal Value.

04/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

BW

201106220

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.26440% or Final Disclosure APR of 8.26400% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

C

201106220

Compliance

Compliance

State Compliance

Maryland HPML Threshold Test

Maryland Higher-Priced Mortgage Loan: APR on subject loan of 8.26440% or Final Disclosure APR of 8.26400% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

C

201106220

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2016-12-02): Received evidence that borrower received disclosure within timing requirements.

12/02/2016

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

C

201106220

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Desk Review / Valuation Report Date: <empty>

Missing CDA or AVM as required by guidelines.

Disposable income of $6283 more than required $3100. 40% DTI on this full documentation loan < 50% guideline max - 10% below program guideline maximum

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

C

201106220

Credit

Credit

Misc

Credit Exception:

Appraised value on delay purchase not allowed when land purchased < 1 year.

Disposable income of $6283 more than required $3100. 40% DTI on this full documentation loan < 50% guideline max - 10% below program guideline maximum

Reviewer Comment (2016-11-29): Client elects to waive.

11/29/2016

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

C

201106220

Property

Property - Appraisal

Appraisal Reconciliation

Value variance greater than 10% between origination appraisal and subsequent product

Desk review yielded an indeterminate result.  A field review was ordered and the value is -16.6667% less than the appraisal value.

3

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

C

C

C

C

Higher Priced QM

Higher Priced QM

No

C

C

201129325

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.33430% or Final Disclosure APR of 7.38300% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201129325

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2016-12-07): Title-Abstract/Title Search was properly disclosure on the amended Loan Estimate dated [MM/DD/YYYY] for $175.00

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201129325

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search.  Fee Amount of $162.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75178)

Reviewer Comment (2016-12-07): Title-Abstract/Title Search was properly disclosure on the amended Loan Estimate dated [MM/DD/YYYY] for $175.00

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201129325

Credit

Loan Package Documentation

Application / Processing

Missing Document: Lender Exception(s) not provided

File does not contain documentation of a lender exception.

Reviewer Comment (2016-12-08): Exception not required.

12/08/2016

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201129325

Credit

Credit

Misc

Credit Exception:

Secondary valuation not provided.

668 representative FICO score > 580 guideline minimum - 88 points above guideline minimum

Reviewer Comment (2016-12-07): Client elects to waive.

12/07/2016

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201129325

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201129325

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Seller Credit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Seller Credit that does not match the Seller Credit from the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Final Closing disclosure does not reflect the seller credit of $750.00 in the Calculating Cash to Close section.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201183022

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $30,647.93, final CD shows $7,500.00.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201183022

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75103)

Reviewer Comment (2017-01-05): This was cured at settlement.

01/05/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201183022

Credit

Credit

Misc

Credit Exception:

Investment Guidelines provided do not allow Foreign Nationals.

Reviewer Comment (2017-01-10): Foreign National guidelines allow for investment properties.

01/10/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201183022

Credit

Credit

Misc

Credit Exception:

Borrower is a FN borrower.  per guides for Non Perm Res Alien: minimum one year history of credit and employment in the United States. Borrower can either have a social security number (SS) or an individual taxpayer identification number (ITIN).  Unable to determine from paperwork if borrower has been working in the US or what is ITIN is

Reviewer Comment (2017-01-10): Guideline quoted is for No Perm REs Aliens, not FN.  This does not apply.

01/10/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201228455

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

39% DTI on this full documentation loan < 50% guideline max - 11% below program guideline maximum

Reviewer Comment (2017-01-12): Client elects to waive.

01/12/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201228455

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.75390% or Final Disclosure APR of 6.75400% is in excess of allowable threshold of APOR 3.24% + 2.5%, or 5.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201228455

Property

Property - Appraisal

Appraisal Reconciliation

Value variance greater than 10% between origination appraisal and subsequent product

Desk review value of $900K is -20% variance from original appraised value of $1.125m.

Reviewer Comment (2017-04-07): A field review was received supporting the original appraisal value.

04/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201264981

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

769 representative FICO score > 680 guideline minimum - 89 points above guideline minimum

Reviewer Comment (2017-02-09): Client elects to waive.

02/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201264981

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.08600% or Final Disclosure APR of 7.09400% is in excess of allowable threshold of APOR 3.61% + 2.5%, or 6.11000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201264981

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly amount reflects $187.25, however prepaid homeowner's insurance reflects $1046.00, should be $2247.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264981

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose number of months for Property Tax under Prepaids. (Final/[MM/DD/YYYY])

Line 4 of Section F, number of months is 0.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264981

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-02): Data correct on subsequent CDs (SFIG).

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264981

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $40,849.00, while closing CD seller's fees total $43,353.82.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264981

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $51.00 exceeds tolerance of $40.00 plus 10% or $44.00.  Sufficient or excess cure was provided to the borrower. (0)

Reviewer Comment (2017-02-02): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

02/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264981

Compliance

Compliance

Miscellaneous Compliance

Rental Income Documentation - Schedule E Method

Qualified Mortgage (Dodd-Frank 2014): Rental income documentation requirement not met for   Lease Agreement and/or Tax Transcripts / Returns not provided. (Non-Subject Investment/Schedule E)

Missing lease agreement.

Reviewer Comment (2017-03-08): Designation switched to Non-QM Reviewer Comment (2017-02-10): While canned exception makes mention of taxes, it's in and/or format.  Reviewers comment state that lease is missing.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201264981

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Missing lease agreement.

Reviewer Comment (2017-03-08): Designation switched to Non-QM

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201264981

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-03-08): Designation switched to Non-QM

03/08/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201264981

Property

Property - Appraisal

Appraisal Reconciliation

Value variance greater than 10% between origination appraisal and subsequent product

Desk Review came back with Indeterminate Value of $0.  No secondary valuation product to support value.

Reviewer Comment (2017-04-11): A field review was received supporting the original appraisal value. Reviewer Comment (2017-04-07): A Field review was received supporting the the original appraisal value.

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201317319

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

The Loan Estimate reflects Title-Environmental Protection Lien and the Final Closing Disclosure reflects Title-Title Endorsement.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201317319

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

The Final Closing Disclosure reflects seller paid fees of $690,813.80. The Seller Disclosure reflects seller paid fees of $116,292.36.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201317319

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $775.00 exceeds tolerance of $700.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-15): Lender provided $585.00 credit at closing for increase in Closing Costs above legal limit.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201317319

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $510.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7507)

Reviewer Comment (2017-02-15): Lender provided $585.00 credit at closing for increase in Closing Costs above legal limit.

02/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201317319

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Borrower on this Full documentation loan has a disposable income of $14,000.00. LTV maximum allowed is 90%-loan closed at 80%.

Reviewer Comment (2017-02-16): Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201317319

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower on this Full documentation loan has a disposable income of $14,000.00. LTV maximum allowed is 90%-loan closed at 80%.

Reviewer Comment (2017-02-16): Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201317319

Credit

Credit

Misc

Credit Exception:

Use of rental income used on departing residence when equity doesn't equal 25%.

Borrower on this Full documentation loan has a disposable income of $14,000.00. LTV maximum allowed is 90%-loan closed at 80%.

Reviewer Comment (2017-02-16): Client elects to waive.

02/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201317319

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-16): All guideline violations have been addressed by lender.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201317319

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-16): All guideline violations have been addressed by lender.

02/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201317321

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.14820% or Final Disclosure APR of 6.14900% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201317321

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.14820% or Final Disclosure APR of 6.14900% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201317321

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201317321

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201317321

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-4,670.00. (9300)

Reviewer Comment (2017-03-13): Credit was applied at closing per settlement statement.  Credit was moved to correct section on post close CD.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201317321

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $67,951.65 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $72,483.29.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201317321

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Borrower on this full documentation loan has a disposable income of $9,215.92 which is above the minimum required amount of $3,850 for an excess of $5,365.92. Guidelines required a 24 month payment history and UW has verified 51 months history with prior mortgage with [REDACTED] and current mortgage with [REDACTED]. Income not being used to qualify is coming from Dividend & Interest income from the 2014 & 2015- 1040's. Interest income in 2014 totaled $31 & in 2015 totaled $1,822. Dividend income in 2014 totaled $5,403 & in 2015 totaled $3,660.

Reviewer Comment (2017-03-13): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201317321

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Lender's Title Insurance.  Fee Amount of $1,205.00 exceeds tolerance of $1,204.00.  Insufficent or no cure was provided to the borrower. (7567)

Fee is reflected in Section B but vendor is no on the SSPL.

Reviewer Comment (2017-03-13): Data correct on subsequent CDs (SFIG).

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201317321

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title fees are shown in Section B: Services Borrower Did Not Shop For, however, borrower did not use providers listed on the SPPL. These fees should have been listed in Section C: Services Borrower Did Shop For.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360012

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status.

The initial application date is [MM/DD/YYYY].  The initial disclosures in file were dated [MM/DD/YYYY].  The file is missing the initial disclosure package.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

RESPA Servicing Disclosure:  Servicing Disclosure Statement Not Provided Within 3 Business Days of Application

RESPA Servicing Disclosure Rule: Creditor did not provide Servicing Disclosure Statement to applicant within three (3) business days of application.

The initial application date is [MM/DD/YYYY].  The initial disclosures in file were dated [MM/DD/YYYY].  The file is missing the initial disclosure package.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule (Dodd-Frank 2014): List of Homeownership Counseling Organizations not provided to applicant within three (3) business days of application.

The initial application date is [MM/DD/YYYY].  The initial disclosures in file were dated [MM/DD/YYYY].  The file is missing the initial disclosure package.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

There are no seller paid fees disclosed on the final CD.

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360012

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt has not been provided.  The earliest CD in the file was dated [MM/DD/YYYY]; however the CD dated [MM/DD/YYYY] identified on the evidence summary is missing.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/[MM/DD/YYYY])

The initial application date is [MM/DD/YYYY].  The initial disclosures in file were dated [MM/DD/YYYY].  The file is missing the initial LE.

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

TILA-RESPA Integrated Disclosure: Borrower did not receive a list of service providers within 3 business days of application.

The initial application date is [MM/DD/YYYY].  The initial disclosures in file were dated [MM/DD/YYYY].  The file is missing the initial disclosure package.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

The initial application date is [MM/DD/YYYY].  The initial disclosures in file were dated [MM/DD/YYYY].  The file is missing the initial disclosure package.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360012

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360012

Credit

Credit

Credit Documentation

Aged document: Credit Report is older than guidelines permit

The credit report is greater than 90 days old at closing.  Note date [MM/DD/YYYY] and CR date [MM/DD/YYYY].

"• 753 FICO • 65% LTV • Purchase Transaction / Primary Occupancy •$172,606 Liquid Cash Reserves •$15,918 Residual Income"

Reviewer Comment (2017-03-27): Client elects to waive. Reviewer Comment (2017-03-20): Document provided is not sufficient to clear exception.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

The disclosure or proof of delivery was not provided in the file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

The disclosure or proof of delivery was not provided in the file.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360012

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360012

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Missing VCC for increase in fee.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360012

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,327.70 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

Missing VCC for increase in fee.

Reviewer Comment (2017-03-28): Seller provided a PCCD, LOX to the borrower, Check and proof of delivery for the tolerance violation of 1,327.70.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360016

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360016

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.40270% or Final Disclosure APR of 5.43800% is in excess of allowable threshold of APOR 3.38% + 1.5%, or 4.88000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360016

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.40270% or Final Disclosure APR of 5.43800% is in excess of allowable threshold of APOR 3.38% + 1.5%, or 4.88000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360016

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Final Closing disclosure is missing the closing date.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360016

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360016

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Final Closing Disclosure reflects that Payees were not provided for Section C line 2, Title Endorsement Fee and line 04 Title Notary fee.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360016

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360025

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360025

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.37760% or Final Disclosure APR of 5.49500% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360025

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.37760% or Final Disclosure APR of 5.49500% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing date is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/140053)

Disclosure reflects ($3596.00), but should be ($4042.00).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-14): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Adjusts Every Starting In

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [MM/DD/YYYY] with an increasing payment disclosed the due date of the first adjustment that does not match the actual due date for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects (14), but should be (13).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Max Amount

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on [MM/DD/YYYY] with an increasing payment disclosed the maximum possible amount of principal and interest that does not match the actual maximum amount for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects ($5166.00), but should be ($5171.00).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 2 that does not match the actual maximum payment for the loan. (ProjSeq:2/140054)

Disclosure reflects ($4785.00), but should be ($4042.00).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 3 that does not match the actual maximum payment for the loan. (ProjSeq:3/140055)

Disclosure reflects ($5166.00), but should be ($4788.00).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Max Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a maximum periodic principal and interest payment for payment stream 4 that does not match the actual maximum payment for the loan. (ProjSeq:4/140056)

Disclosure reflects ($5166.00), but should be ($5171.00).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Projected Principal And Interest Payment Min Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a periodic principal and interest payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/140053)

Disclosure reflects ($2550.00), but should be ($2995.85).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

Disclosure reflects TIP of (99.006%) but calculated TIP is (98.993%).  Used Index Value = (1.240%) per (ComplianceEase) document in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for (Tax Service fee) of ($10.00) was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $72.00 exceeds tolerance of $62.00.  Insufficent or no cure was provided to the borrower. (7580)

Fee disclosed as ($62.00) on (LE dated [MM/DD/YYYY]), but disclosed as ($72.00) on Final Closing Disclosure.

Reviewer Comment (2017-03-24): Received all required cure documentation. Reviewer Comment (2017-03-13): Received copy of check and LOE to borrower.  However CD was not for this file.

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360025

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360036

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360036

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.40130% or Final Disclosure APR of 5.44200% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360036

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.40130% or Final Disclosure APR of 5.44200% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360036

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/140368)

Disclosure reflects ($730.78), but should be ($796.58).

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360036

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/140369)

Disclosure reflects ($730.78), but should be ($796.58).

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360036

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/140370)

Disclosure reflects ($730.78), but should be ($796.58).

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360036

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/140371)

Disclosure reflects ($730.78), but should be ($796.58).

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360036

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/140368)

Disclosure reflects ($3215.70), but should be ($3281.50).

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360036

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $47,682.60, while closing CD seller's fees total $0.00.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360036

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing Date is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360036

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360036

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-03-13): Received evidence that borrower received appraisal within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360036

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360036

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.40130% or Final Disclosure APR of 5.44200% is in excess of allowable threshold of APOR 3.26% + 1.5%, or 4.76000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360057

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360057

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.67250% or Final Disclosure APR of 5.70400% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360057

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.67250% or Final Disclosure APR of 5.70400% is in excess of allowable threshold of APOR 3.33% + 1.5%, or 4.83000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360057

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

The closing date field has been left blank on the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360057

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

There are no seller paid fees disclosed on the combined CD or the signed seller CD.  The estimated seller CD on page 154 disclosed $16,900.00 in seller paid costs.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360057

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the note.  The final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360057

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

LE disclosed the Notary fee as 'Titlle - Notary Fee'.  The final CD did not disclose the notary fee as a Title fee.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360057

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

The original appraisal report dated[MM/DD/YYYY] is not signed by the appraiser.

Reviewer Comment (2017-03-13): Received executed appraisal.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360057

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Purchase agreement extension provided on page 500 extends the contract through July 22, 2016.  The loan did not close until [MM/DD/YYYY].  The purchase contract is expired.

Reviewer Comment (2017-03-28): See new non-material Exception. Reviewer Comment (2017-03-13): Received extension through 8/22.  Missing extension that allows a closing on 10/12/16.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201360057

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

TILA-RESPA Integrated Disclosure: Settlement Service Provider List did not provide at least one available provider for each settlement service borrower is entitled to shop for or inform borrower they may choose different provider from list.

There are no providers or services disclosed on the Settlement Service Provider List.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360057

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $625.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-21): Cured at closing.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360057

Compliance

Compliance

Miscellaneous Compliance

Miscellaneous Compliance:  Non-Material Compliance Exception:

Purchase agreement extension provided on page 500 extends the contract through July 22, 2016.  The loan did not close until [MM/DD/YYYY].  The purchase contract is expired at time of Closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201360060

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.74780% or Final Disclosure APR of 5.75900% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360060

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

The Note and security instrument disclosed a closing date of [MM/DD/YYYY].  The final CD disclosed a closing date of [MM/DD/YYYY] and was signed on [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360060

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360060

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360060

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

Asset statements are over 120 days old and have been removed from available assets.   ([REDACTED])

Reviewer Comment (2017-03-13): Received updated statements within timing requirements.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360060

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.74780% or Final Disclosure APR of 5.75900% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360060

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  Final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360060

Credit

Credit

Misc

Credit Exception:

Lender guideline requires an additional identification verification when Permanent Resident Alien Card is used as primary form of ID in the form of a utility or insurance bill.  Borrowers address on drivers license is his business address.

Reviewer Comment (2017-03-28): Seller provided secondary ID. Reviewer Comment (2017-03-13): Insurance document is for subject transaction.  Missing utility bill from previous residence.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360060

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $250.00 exceeds tolerance of $150.00.  Sufficient or excess cure was provided to the borrower at Closing. (75103)

Fee disclosed as $150.00 on LE dated[MM/DD/YYYY], but disclosed as $250.00 on Final CD.

Reviewer Comment (2017-02-21): $100.00 tolerance cure was issued to borrower on Final CD.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360062

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360062

Credit

Credit

Credit Documentation

Aged document: Primary Valuation is older than guidelines permit

Valuation Type: Appraisal / Valuation Report Date: [MM/DD/YYYY]

Note date [MM/DD/YYYY], report date [MM/DD/YYYY].

"• 66 FICO • 54.29% LTV • Purchase Transaction / Primary Occupancy •$11,024 Residual Income"

Reviewer Comment (2017-03-27): Client elects to waive. Reviewer Comment (2017-03-20): Document provided is not sufficient to clear exception. Reviewer Comment (2017-03-14): The violation is due to the appraisal being older than 90 days from Note Date.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360062

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64170% or Final Disclosure APR of 5.68700% is in excess of allowable threshold of APOR 3.28% + 1.5%, or 4.78000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360062

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from  that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360062

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64170% or Final Disclosure APR of 5.68700% is in excess of allowable threshold of APOR 3.28% + 1.5%, or 4.78000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360062

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-15): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360062

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360085

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

1003 Error: Citizenship Source Documentation  was not provided

Borrower is  permanent resident alien, per guidelines a valid permanent resident card is required and is missing from file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360085

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $23.02 exceeds tolerance of $20.00.  Insufficent or no cure was provided to the borrower. (7520)

Fee disclosed as $20 on LE dated[MM/DD/YYYY], but disclosed as $23.02 on Final Closing Disclosure. Fee disclosed as $23.02 on Initial CD dated [MM/DD/YYYY] but no valid COC was provided.

Reviewer Comment (2017-03-24): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2017-03-14): Received document showing baseline amount for credit report was $20.03, however this amount is not reflected on any disclosure provided.  Cure was short by $.03 unless disclosure with that baseline amount is provided.

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360085

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64530% or Final Disclosure APR of 5.66700% is in excess of allowable threshold of APOR 3.35% + 1.5%, or 4.85000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360085

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360085

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Tolerance Cure of $2.99 for Credit report fee was insufficient to cure $3.02 violation.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360085

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

Closing date on Final CD is blank.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360085

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/[MM/DD/YYYY])

Verification on borrowers receipt of updated appraisal with a report date of [MM/DD/YYYY] was not provided.  Appraisal acknowledgement reflects a receipt date of [MM/DD/YYYY]. Appraisal on page 37 has a report date of [MM/DD/YYYY] and report on page 77 has a report date of [MM/DD/YYYY].; page 551 has a report date of [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360085

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360085

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64530% or Final Disclosure APR of 5.66700% is in excess of allowable threshold of APOR 3.35% + 1.5%, or 4.85000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360085

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360086

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.53100% or Final Disclosure APR of 0.00000% is in excess of allowable threshold of APOR 3.17% + 1.5%, or 4.67000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360086

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.53100% or Final Disclosure APR of 0.00000% is in excess of allowable threshold of APOR 3.17% + 1.5%, or 4.67000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360086

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Closing Disclosures in the Loan File

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided or Closing Disclosure not provided prior to closing.  Any applicable Federal, State or Local compliance testing is unreliable or not performed.

Missing final CD. CD in file was issued post closing.

Reviewer Comment (2017-03-22): Received final CD. Reviewer Comment (2017-03-14): Received same CD as in original file.  Issue date of 10/24 is 4 days after closing.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360086

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

The file is missing the CHARM Booklet.

Reviewer Comment (2017-03-15): Downgraded from an EV3 to an EV2 based on the attestation from  that they provided the Disclosure to the consumer within 3 days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360086

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

The file is missing a copy of the appraisal report.

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360086

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

The file is missing a copy of the appraisal report.

Reviewer Comment (2017-03-14): Received copy of appraisal.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360086

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360086

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Unable to determine due to appraisal report is missing from the loan file.

Reviewer Comment (2017-03-22): Received copy of appraisal.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360086

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

The file is missing a copy of the appraisal report.

Reviewer Comment (2017-03-22): Received copy of appraisal.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360086

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.53100% or Final Disclosure APR of 0.00000% is in excess of allowable threshold of APOR 3.17% + 1.5%, or 4.67000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360086

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Missing copy of initial CD.

Reviewer Comment (2017-03-28): Received evidence that borrower received disclosure within timing requirements.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

A

A

A

A

A

Non QM

Non QM

No

C

B

201360086

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360098

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360098

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.69390% or Final Disclosure APR of 5.73200% is in excess of allowable threshold of APOR 3.18% + 2.5%, or 5.68000%.  Compliant Higher Priced Mortgage Loan.

Loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360098

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account Statement Missing

RESPA (2010): Initial escrow account statement was not provided to the borrower.

Initial escrow account disclosure has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360098

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.69390% or Final Disclosure APR of 5.73200% is in excess of allowable threshold of APOR 3.18% + 2.5%, or 5.68000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360098

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/141028)

Lender used $125.00 monthly for Homeowner's insurance premium. Actual premium is $118.67 monthly per insurance documents in file. Title reflects monthly taxes of $1,131.93. Final Closing Disclosure reflects $1,343.70 monthly. File does not contain documentation to support this amount.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360098

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/141029)

Lender used $125.00 monthly for Homeowner's insurance premium. Actual premium is $118.67 monthly per insurance documents in file. Title reflects monthly taxes of $1,131.93. Final Closing Disclosure reflects $1,343.70 monthly. File does not contain documentation to support this amount.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360098

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/141030)

Lender used $125.00 monthly for Homeowner's insurance premium. Actual premium is $118.67 monthly per insurance documents in file. Title reflects monthly taxes of $1,131.93. Final Closing Disclosure reflects $1,343.70 monthly. File does not contain documentation to support this amount.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360098

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/141031)

Lender used $125.00 monthly for Homeowner's insurance premium. Actual premium is $118.67 monthly per insurance documents in file. Title reflects monthly taxes of $1,131.93. Final Closing Disclosure reflects $1,343.70 monthly. File does not contain documentation to support this amount.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360098

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/141028)

Lender used $125.00 monthly for Homeowner's insurance premium. Actual premium is $118.67 monthly per insurance documents in file. Title reflects monthly taxes of $1,131.93. Final Closing Disclosure reflects $1,343.70 monthly. File does not contain documentation to support this amount.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360098

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Sellers CD has not been provided in the loan documents.  Final combined CD does not disclose any seller paid fees.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360098

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Change - Deposit

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether there was a change in the Deposit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 3060.  LE was properly rounded.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360098

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt has not been provided in the loan documents.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360098

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Missing required "Title - " verbiage on the following fees:  Document Preparation Fee, Endorsement Fee, Lenders Coverage Premium and Notary Fee.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360098

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Disclosure reflects a negative fee for -75.00 in Section B.  This is TRID non-compliant.

Reviewer Comment (2017-03-09): Allowed when appraisal POC.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201360098

Credit

Credit

Misc

Credit Exception:

Lender guideline requires additional identification when Permanent Resident Alien card is used as primary identification.  Utility or Insurance bill have not been provided.  Borrowers address on drivers license, insurance for investment properties differs from address on 1003.

Reviewer Comment (2017-03-28): Secondary ID was provided.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360098

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set was not provided.  In order to determine Average Prime Offer Rate (APOR), the worst case scenario was used between Application Date and Transaction Date.

Rate lock has not been provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360108

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.64930% or Final Disclosure APR of 5.68700% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360108

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.64930% or Final Disclosure APR of 5.68700% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360108

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

CD Issue Date [MM/DD/YYYY] > Closing Date Less 6 days [MM/DD/YYYY] and CD Received Date [MM/DD/YYYY] is not null and CD Received Date [MM/DD/YYYY] > Closing Date Less 3 days [MM/DD/YYYY].

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360108

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/140851)

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG). Reviewer Comment (2017-03-22): Upload on 3/21 is not for this file.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/140852)

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/140853)

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/140854)

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/140851)

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360137

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360137

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.63180% or Final Disclosure APR of 5.66800% is in excess of allowable threshold of APOR 3.29% + 1.5%, or 4.79000%.  Compliant Higher Priced Mortgage Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360137

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.63180% or Final Disclosure APR of 5.66800% is in excess of allowable threshold of APOR 3.29% + 1.5%, or 4.79000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360137

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Note and security instrument disclose a closing date of [MM/DD/YYYY].  Final CD was issued on [MM/DD/YYYY] and disclosed a closing date of [MM/DD/YYYY].  Consummation occurred on [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360137

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $39,975.54, while closing CD seller's fees total $-0-.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360137

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360137

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Purchase contract disclosed closing date of 45 days from acceptance of contract date of[MM/DD/YYYY] which is [MM/DD/YYYY].  Loan did not close until [MM/DD/YYYY].  Purchase agreement is out of contract, extension has not been provided.

Reviewer Comment (2017-03-28): See new Non-material Exception.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201360137

Compliance

Compliance

Miscellaneous Compliance

Miscellaneous Compliance:  Non-Material Compliance Exception:

Purchase contract disclosed closing date of 45 days from acceptance of contract date of[MM/DD/YYYY] which is [MM/DD/YYYY].  Loan did not close until [MM/DD/YYYY].  Purchase agreement is out of contract, extension has not been provided.  Contract was expired at closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201360149

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

The appraisal has not been provided in the loan documents.

Reviewer Comment (2017-03-15): Received copy of appraisal

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.66790% or Final Disclosure APR of 5.68200% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Loan.

The loan is higher priced as indicated on the compliance report provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

The closing date field has been left blank on the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360149

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on [MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

The notary fee was disclosed on the LE as a Title fee.  The CD does not disclose this as a Title fee.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360149

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $26,078.78while closing CD seller's fees total $-0-.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360149

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Purchase agreement is valid 45 days from acceptance date of [MM/DD/YYYY] which is [MM/DD/YYYY].  Consummation did not take place until [MM/DD/YYYY].  Purchase agreement is out of contract, extension has not been provided.

Reviewer Comment (2017-03-28): See new Non-Material Exception.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201360149

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

Reviewer Comment (2017-03-21): Received CDA with value within tolerance.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360149

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Primary appraisal is missing from the loan documents.

Reviewer Comment (2017-03-15): Received copy of appraisal

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Assumption language is present on the Note.  The final CD disclosed that the loan is not assumable.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360149

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Borrower was allowed to shop for services, utilized the vendor disclosed on the SSPL.  Fees are incorrectly disclosed in section C on the final CD, should be under section B.  Notary fee does not indicate  'paid to' in section C.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360149

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Occupancy discrepancy.

The borrower does not intend to occupy as a primary residence within 60 days of closing.  Lease after sale addendum provided with the purchase agreement dated [MM/DD/YYYY] allows sellers to rent through at least[MM/DD/YYYY].  RLAS addendum 1 dated [MM/DD/YYYY] indicates the buyer as the tenant and the seller as the landlord.  Note date is [MM/DD/YYYY]

"• 761 FICO • 55.56% LTV • Purchase Transaction / Primary Occupancy •$109,142 Liquid Cash Reserves "

Reviewer Comment (2017-03-27): Client elects to waive.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.66790% or Final Disclosure APR of 5.68200% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-23): Received evidence that borrower received appraisal within timing requirements.

03/23/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

The file was missing a copy of the appraisal and proof of delivery or a waiver at least 3 business days prior to closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Reviewer Comment (2017-03-15): Reset exception.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-03-23): Received evidence that borrower received appraisal within timing requirements.

03/23/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Date received is blank.

Reviewer Comment (2017-03-23): Received evidence that borrower received appraisal within timing requirements.

03/23/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.66790% or Final Disclosure APR of 5.68200% is in excess of allowable threshold of APOR 3.27% + 1.5%, or 4.77000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360149

Compliance

Compliance

Miscellaneous Compliance

Miscellaneous Compliance:  Non-Material Compliance Exception:

Purchase agreement is valid 45 days from acceptance date of [MM/DD/YYYY] which is [MM/DD/YYYY].  Consummation did not take place until [MM/DD/YYYY].  Purchase agreement is out of contract, extension has not been provided.  Contract expired at time of Closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201360157

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDAs within variance tolerance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360157

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-03-28): Received evidence that borrower received appraisal within timing requirements.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360157

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.75300% or Final Disclosure APR of 5.78700% is in excess of allowable threshold of APOR 3.37% + 1.5%, or 4.87000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-28): Received evidence that borrower received appraisal within timing requirements.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360157

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-03-28): Received evidence that borrower received appraisal within timing requirements.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360157

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.75300% or Final Disclosure APR of 5.78700% is in excess of allowable threshold of APOR 3.37% + 1.5%, or 4.87000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360157

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360157

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the Closing Date. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360157

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $47,130.32 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360157

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.75300% or Final Disclosure APR of 5.78700% is in excess of allowable threshold of APOR 3.37% + 1.5%, or 4.87000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360169

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

The appraisal is missing the 1004MC and the appraiser's e-mail address.

Reviewer Comment (2017-03-23): Received copy of 1004MC.

03/23/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360169

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360169

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360169

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $178,461 while closing CD seller's fees total $0.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360169

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360169

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $950.00 exceeds tolerance of $800.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Fee disclosed as $800 on the LE dated [MM/DD/YYYY], but disclosed as $950 on the Final Closing Disclosure.

Reviewer Comment (2017-02-27): Cure of $150 was provided on final closing statement

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360169

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $36.04 exceeds tolerance of $25.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Fee disclosed as $25 on the LE dated [MM/DD/YYYY], but disclosed as $36.04 on the Final Closing Disclosure.

Reviewer Comment (2017-02-27): Cure for $11.04 was provided on final closing disclosure

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360169

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $132.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as $62 on the LE dated [MM/DD/YYYY], but disclosed as $132 on the Final Closing Disclosure.

Reviewer Comment (2017-02-27): Cure for fee was provided on final Closing Disclousure

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360169

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360170

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360170

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $122,824.77 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360170

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Lender's tracking worksheet indicates an initial CD was provided on [MM/DD/YYYY]. This CD was not provided for review.

Reviewer Comment (2017-03-28): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-09): CD already reviewed in original submission.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360170

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-27): This was cured at settlement

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360170

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360174

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360174

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.75860% or Final Disclosure APR of 5.78700% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360174

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and missing seller's CD.

Reviewer Comment (2017-03-22): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-20): Disclosure sent in is buyer's settlement statement and doesn't reflect seller fees.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360174

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-24): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-09): CD provided as stip was final which was already provided, still missing initial.

03/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360174

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.75860% or Final Disclosure APR of 5.78700% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360174

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $82.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-28): Lender provided $20.00 credit at closing for increase in Closing Costs above legal limit.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201360185

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360185

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360185

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.67820% or Final Disclosure APR of 5.68300% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360185

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.67820% or Final Disclosure APR of 5.68300% is in excess of allowable threshold of APOR 3.34% + 1.5%, or 4.84000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360185

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $9,855.03 were disclosed on the seller's CD.

Reviewer Comment (2017-03-24): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-20): Disclosure sent in is buyer's settlement statement and doesn't reflect seller fees. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360188

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360188

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.78990% or Final Disclosure APR of 5.82400% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360188

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.78990% or Final Disclosure APR of 5.82400% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360188

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD reflects closing date of [MM/DD/YYYY], vs actual consummation date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360188

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $23,769.95 were disclosed on the seller's CD.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360188

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for 10% tolerance violation of $205.00 was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360188

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360188

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $205.00 exceeds tolerance of $0.00 plus 10% or $0.00.  Insufficient or no cure was provided to the borrower. (0)

$205 violation due to Recording Fee which was collected on Final CD, but was not disclosed on the LE.

Reviewer Comment (2017-03-28): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360190

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360190

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360190

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360190

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.77240% or Final Disclosure APR of 5.80800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-22): Received copy of appraisal.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360190

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Reviewer Comment (2017-03-22): Received copy of appraisal.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360190

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2017-03-22): Received copy of appraisal.

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360190

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.77240% or Final Disclosure APR of 5.80800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360190

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of ([MM/DD/YYYY]), but transaction consummation (mortgage notary) date was ([MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360190

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/145198)

Disclosure reflects ($653.71), but should be ($636.08).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360190

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/145199)

Disclosure reflects ($653.71), but should be ($636.08).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360190

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/145200)

Disclosure reflects ($653.71), but should be ($636.08).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360190

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/145201)

Disclosure reflects ($653.71), but should be ($636.08).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360190

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/145198)

Disclosure reflects ($2655.56), but should be ($2637.93).

Reviewer Comment (2017-03-24): Data correct on subsequent CDs (SFIG).

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360190

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Final CD does not reflect any Seller paid fees.

Reviewer Comment (2017-03-20): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360190

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360190

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201360190

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.77240% or Final Disclosure APR of 5.80800% is in excess of allowable threshold of APOR 3.24% + 1.5%, or 4.74000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360199

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360199

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.84420% or Final Disclosure APR of 5.87100% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360199

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

The file is missing the appraisal report.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201360199

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

The file is missing the appraisal report.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360199

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.84420% or Final Disclosure APR of 5.87100% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360199

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $36,538.60, while closing CD seller's fees total $0.

Reviewer Comment (2017-03-16): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360199

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360199

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

The file is missing the appraisal report.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360199

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360199

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.84420% or Final Disclosure APR of 5.87100% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360199

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2017-03-27): Updated guidance from lender requires coverage at the lower of replacement cost or loan amount.  Coverage sufficient. Reviewer Comment (2017-03-22): Received HOI documents but coverage is not sufficient to cover Dwelling Cost New amount of $739000.

03/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360202

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360202

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.83810% or Final Disclosure APR of 5.85800% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360202

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Appraisal missing from file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360202

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Appraisal missing from file.

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360202

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.83810% or Final Disclosure APR of 5.85800% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360202

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360202

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Monthly amount reflects $59.22, however prepaid homeowner's insurance reflects $735.64, should be $710.64.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360202

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $39,105.61, while closing CD seller's fees total $2,459.80.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360202

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

Valuation Type: Appraisal / Valuation Report Date: <empty>

Reviewer Comment (2017-03-15): Received copy of appraisal.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360202

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.83810% or Final Disclosure APR of 5.85800% is in excess of allowable threshold of APOR 3.36% + 1.5%, or 4.86000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360202

Credit

Loan Package Documentation

Application / Processing

Valuation Error: APN Number not provided.

Valuation Type: Appraisal / Valuation Report Date: [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201360202

Credit

Insurance

Insurance Documentation

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2017-03-27): Updated guidance from lender requires coverage at the lower of replacement cost or loan amount.  Coverage sufficient. Reviewer Comment (2017-03-24): Coverage not sufficient for appraisal replacement cost. Reviewer Comment (2017-03-22): Coverage amount does not cover the Dwelling Replacement Cost on appraisal of $508800.

03/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201360211

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360211

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.73880% or Final Disclosure APR of 5.75800% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360211

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-24): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-09): All CDs provided were already reviewed in original submission.

03/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360211

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.73880% or Final Disclosure APR of 5.75800% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360211

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360211

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of  [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360211

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

The final CD reflects Homeowner's Insurance Premium, Prepaids, collected at 12 months totalling $638 vs. actual $626.04.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360211

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $62,979, while closing CD seller's fees total $726.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360217

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Not provided

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360217

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 5.75150% or Final Disclosure APR of 5.77100% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Loan.

California Higher-Priced Loan: APR on subject loan of 5.75150% or Final Disclosure APR of 5.77100% is in excess of allowable threshold of APOR 3.43% + 1.5%, or 4.93000%. Compliant Higher Priced Loan

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201360217

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360217

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

TILA-RESPA Integrated Disclosure: Seller Closing Disclosure not located in the file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360217

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.75150% or Final Disclosure APR of 5.77100% is in excess of allowable threshold of APOR 3.39% + 1.5%, or 4.89000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201360217

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/[MM/DD/YYYY])

CD in file issued on [MM/DD/YYYY] but is a draft and not sent to borrower.

Reviewer Comment (2017-03-24): Received evidence that borrower received disclosure within timing requirements. Reviewer Comment (2017-03-22): Same CD uploaded as previously reviewed.  Missing initial CD. Reviewer Comment (2017-03-09): Cds provided were already reviewed in original submission.

03/24/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360217

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360220

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-03-20): Received copy of CDA with no variance.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360220

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

No seller paid fees were on the borrower's CD and $64,058.80 were disclosed on the seller's CD.

Reviewer Comment (2017-03-22): Performed compliance review with Seller paid Fees from an alternative source document. Downgraded exception to EV2-B. Reviewer Comment (2017-03-20): Disclosure sent in is buyer's settlement statement and doesn't reflect seller fees. Reviewer Comment (2017-03-17): Missing Seller CD from imaged file

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201360220

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-03-09): Received evidence that borrower received disclosure within timing requirements.

03/09/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201360220

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

Note and ARM rider identify the loan can be assumed; final CD states the loan cannot be assumed.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201360220

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $112.00 exceeds tolerance of $62.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Fee disclosed as $62.00 on LE dated [MM/DD/YYYY], but disclosed as $112.00 on Final CD.

Reviewer Comment (2017-02-28): $50.00 tolerance cure was issued on Final CD.

02/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201390297

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Section F shows Homeowner's Insurance Premium of $1,218.00 for 12 months or $101.50 per month. Section G shows monthly escrow payment of $169.17.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201390297

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Total Closing Costs did not exceed the legal limit

Reviewer Comment (2017-02-16): Erroneous Reg ID 3060.  This fee was seller paid, and is customarily paid by Seller in the state of CA.

02/16/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201390297

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-02-17): Received evidence that borrower received disclosure within timing requirements.

02/17/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

N/A

N/A

No

C

B

201390297

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on [MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-02-17): Received evidence that borrower received disclosure within timing requirements.

02/17/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

N/A

N/A

No

C

B

201390297

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $194,426.64 and Closing Disclosure Calculated Closing  Costs Subtotals Paid By Seller At Closing $134,256.14.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201390761

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201390761

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-02-17): Lender cured exception by refunding $150.00 to borrower at closing.

02/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

B

B

201392356

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Overall primary housing decrease from $4783 to $4053 Residual income of $7,700 is in excess of required of $3,700 40 months of reserves in excess of required 3 months LTV of 75% is below program maximum of 90%

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201392356

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-21): All guideline violations have been addressed by client.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201392356

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI > 50% - Lender approved.

Reviewer Comment (2017-02-21): All guideline violations have been addressed by client.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201392356

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Reviewer Comment (2017-02-20): Lender cured with re-disclosed LE dated [MM/DD/YYYY] and subsequent LE's and CD's having consistent table usage.

02/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392356

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved

Overall primary housing decrease from $4783 to $4053 Residual income of $7,700 is in excess of required of $3,700 40 months of reserves in excess of required 3 months LTV of 75% is below program maximum of 90%

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201392356

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $40.00 exceeds tolerance of $22.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-02-21): Cured at closing.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201392357

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Guideline variance approved by lender at time of origination. Max DTI is 50%; loan is at 53.99461%.

Borrower on this Full documentation loan has a disposable income of $3473.95; Minimum required is $1900. LTV of 62.988% is significantly below guideline max of 85% for 704 FICO score.

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201392357

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this Full documentation loan has a disposable income of $3473.95; Minimum required is $1900. LTV of 62.988% is significantly below guideline max of 85% for 704 FICO score.

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201392357

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.51320% or Final Disclosure APR of 6.51300% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Non-Compliant Higher Priced Mortgage Loan.

APR on subject loan of 6.51320% or Final Disclosure APR of 6.51300% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%. Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-02-21): All guideline violations have been addressed by client.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201392357

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Lender approved DTI Exception above guideline max.

Reviewer Comment (2017-02-21): All guideline violations have been addressed by client.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201392357

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Lender approved DTI Exception above guideline max.

Reviewer Comment (2017-02-21): All guideline violations have been addressed by client.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201392357

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Lender approved DTI Exception above guideline max.

Reviewer Comment (2017-02-21): All guideline violations have been addressed by client.

02/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201392357

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.51320% or Final Disclosure APR of 6.51300% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Higher Priced Loan.

APR on subject loan of 6.51320% or Final Disclosure APR of 6.51300% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%. Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201392357

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date of [MM/DD/YYYY] that did not match the actual date of consummation on [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392357

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Total Closing Costs did not exceed the legal limit

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392357

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,497.00. (9300)

Reviewer Comment (2017-02-27): Received VCC reflecting Credit being reduced to $0.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201392357

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

Seller Closing Disclosure not located in the file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392357

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.51320% or Final Disclosure APR of 6.51300% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201392358

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

715 credit score > 680 minimum credit score-35 points above guideline requirement. 37.80% DTI on this (Documentation Type) documentation loan < 50% guideline max - 12.20% below program guideline maximum

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201392358

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.62000% or Final Disclosure APR of 6.62000% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201392358

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.62000% or Final Disclosure APR of 6.62000% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201392358

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392358

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $49,087.86, while closing CD seller's fees total $623,796.07.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392359

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved

Guideline variance approved by lender at time of origination. Credit score required for 90% LTV is 680, actual 674. Lender LTV exception to allow up to 90% LTV when program maximum is 85% LTV based on the following compensating factors: Residual income required is $5,980, actual verified is $14,475. Stable employment for B1, 12 years same employer. Primary housing payment history past 36 months 0x30. Borrower has employment stability for 18 years as an [REDACTED]. Borrower has job stability for 12 years with the same employer, as an [REDACTED]. 22.29 months reserves > 6 months guideline minimum - borrowers have verified reserves of $122,038.95.

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201392359

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Guideline variance approved by lender at time of origination. Credit score required for 90% LTV is 680, actual 674. Lender LTV exception to allow up to 90% LTV when program maximum is 85% LTV based on the following compensating factors: Residual income required is $5,980, actual verified is $14,475. Stable employment for B1, 12 years same employer. Primary housing payment history past 36 months 0x30. Borrower has employment stability for 18 years as an [REDACTED]. Borrower has job stability for 12 years with the same employer, as an [REDACTED]. 22.29 months reserves > 6 months guideline minimum - borrowers have verified reserves of $122,038.95.

Reviewer Comment (2017-03-09): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201392359

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.48240% or Final Disclosure APR of 6.48200% is in excess of allowable threshold of APOR 3.51% + 2.5%, or 6.01000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201392359

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-03-02): Designation switched to Non-QM

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201392359

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Reviewer Comment (2017-03-02): Designation switched to Non-QM

03/02/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201392359

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.48240% or Final Disclosure APR of 6.48200% is in excess of allowable threshold of APOR 3.51% + 2.5%, or 6.01000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

No

C

B

201392359

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $2772.62.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201392359

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201392359

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75103)

Fee not disclosed on LE dated [MM/DD/YYYY] and disclosed as $150 on Final CD.  Note:  Per COC in file Lender was notified of change on [MM/DD/YYYY], however re-disclosed LE was not issued until [MM/DD/YYYY].

Reviewer Comment (2017-03-09): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201392359

Credit

Credit

Credit Eligibility

Credit Issue:  Charged off accounts on credit report were not satisfied at closing per loan approval.

Lender approved

Guideline variance approved by lender at time of origination. Credit score required for 90% LTV is 680, actual 674. Lender LTV exception to allow up to 90% LTV when program maximum is 85% LTV based on the following compensating factors: Residual income required is $5,980, actual verified is $14,475. Stable employment for B1, 12 years same employer. Primary housing payment history past 36 months 0x30. Borrower has employment stability for 18 years as an [REDACTED]. Borrower has job stability for 12 years with the same employer, as an [REDACTED]. 22.29 months reserves > 6 months guideline minimum - borrowers have verified reserves of $122,038.95.

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201392359

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on [MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

No

C

B

201392359

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,622.62 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Fee not disclosed on LE.  Note:  COC in file indicates Courtesy re-disclosure reflecting the increase in discount fees, however no reason for change was given.

Reviewer Comment (2017-03-26): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2017-03-09): Received CoC stating fee was added at closing [MM/DD/YYYY] CD due to extending a rate lock.  However, rate lock extension on [MM/DD/YYYY] shows rate was locked through [MM/DD/YYYY], so no extension was necessary.  Exception remains.

03/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201392359

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-03-02): Designation switched to Non-QM

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201392360

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

PASS: Required $6,350.00; Actual $19,072.24; Difference $12,722.24. Max is 50% and we are at 32.52%. 37 months of satisfactory rent payment have been verified with VOR in file. Only required 12 months.

Reviewer Comment (2017-03-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201392360

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.77740% or Final Disclosure APR of 6.77700% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

HPML per lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201392360

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.77740% or Final Disclosure APR of 6.77700% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Loan.

HPML per lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201392360

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201392360

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-02-20): This was cured at closing.

02/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201392360

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

2.35 months reserves is less than 9 months required by guidelines. Lender approved exception was provided.

PASS: Required $6,350.00; Actual $19,072.24; Difference $12,722.24. Max is 50% and we are at 32.52%. 37 months of satisfactory rent payment have been verified with VOR in file. Only required 12 months.

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201392362

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

23 months reserves > 3 months guideline minimum

Reviewer Comment (2017-02-21): Client elects to waive.

02/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201392362

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.18650% or Final Disclosure APR of 6.18700% is in excess of allowable threshold of APOR 3.51% + 2.5%, or 6.01000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201392362

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.18650% or Final Disclosure APR of 6.18700% is in excess of allowable threshold of APOR 3.51% + 2.5%, or 6.01000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201392362

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD shows closing date as [MM/DD/YYYY] with disbursement date of [MM/DD/YYYY]; Loan documents were signed by borrower on [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392362

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $12.50.

Reviewer Comment (2017-03-07): Fee payee corrected and no longer subject to 0% testing.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392362

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $12.50 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75197)

Fee not disclosed on LE.

Reviewer Comment (2017-03-07): Fee payee was updated to reflect vendor on SSPL, so no longer subject to 0% tolerance testing. Reviewer Comment (2017-03-02): Received CoC, however, "Courtesy Re-Disclosure" isn't a valid reason to add a fee.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201392362

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Settlement, E-Recording and Mobile Notary fee reflected in section B, should be in section C.  Providers used are not listed on SSPL.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201392362

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $86,526.78.  Borrower's CD reflects $87,931.87.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201395776

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

31 months reserves > 9 months guideline minimum

Reviewer Comment (2017-03-09): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/09/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201395776

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for 0% tolerance violations $150 was not provided.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395776

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $14,978.70, while closing CD seller's fees total $3,750.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395776

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $500.00 exceeds tolerance of $475.00.  Insufficent or no cure was provided to the borrower. (7506)

Sufficient cure provided on final CD of $25.00.

Reviewer Comment (2017-02-22): Lender provided $36.24 credit at closing for increase in Closing Costs above legal limit.

02/22/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395776

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee disclosed as $0 on LE dated [MM/DD/YYYY], but disclosed as $150 on Final Closing Disclosure. Lender is bound by Broker's LE unless a valid change of circumstance occured. No valid change of circumstance occured between [MM/DD/YYYY] LE and [MM/DD/YYYY] LE.

Reviewer Comment (2017-03-09): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/09/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395776

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $34.24 exceeds tolerance of $23.00.  Insufficent or no cure was provided to the borrower. (7520)

Sufficient cure provided on final CD of $11.24.

Reviewer Comment (2017-02-22): Lender provided $36.24 credit at closing for increase in Closing Costs above legal limit.

02/22/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395776

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title fees are listed in Section B: Services Borrower Did Not Shop For, however, borrower did not use provider listed on the SPPL. These fees should have been in Section C: Services Borrower Did Shop For.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201395779

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

76 months reserves > 9 months guideline minimum

Reviewer Comment (2017-02-23): Client elects to waive.

02/23/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

N/A

No

C

B

201395779

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201395779

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on[MM/DD/YYYY] reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section. (Final/[MM/DD/YYYY])

Flood Cert Fee is marked as paid to the Lender.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201395779

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Servicing Missing

TILA-RESPA Integrated Disclosure - Other Considerations: Loan Estimate provided on [MM/DD/YYYY] did not disclose the Servicing statement. (Initial/[MM/DD/YYYY])

Loan Estimate provided on [MM/DD/YYYY] did not disclose an intent for servicing

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201395779

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Servicing Missing

TILA-RESPA Integrated Disclosure - Other Considerations: Loan Estimate provided on [MM/DD/YYYY] did not disclose the Servicing statement. (Interim/[MM/DD/YYYY])

Loan Estimate provided on[MM/DD/YYYY] did not disclose an intent for servicing

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201395779

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Servicing Missing

TILA-RESPA Integrated Disclosure - Other Considerations: Loan Estimate provided on [MM/DD/YYYY] did not disclose the Servicing statement. (Interim/[MM/DD/YYYY])

Loan Estimate provided on [MM/DD/YYYY] did not disclose an intent for servicing

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201395779

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Servicing Missing

TILA-RESPA Integrated Disclosure - Other Considerations: Loan Estimate provided on [MM/DD/YYYY] did not disclose the Servicing statement. (Interim/[MM/DD/YYYY])

Loan Estimate provided on [MM/DD/YYYY] did not disclose an intent for servicing

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

C

B

201395779

Compliance

Compliance

Federal Compliance

Investment Property Submitted as QM

Qualified Mortgage (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Qualified Mortgage requirements.

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

No

C

B

201395780

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

B

B

201395780

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $288.75 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-02-23): Lender provided $288.75 credit at closing for increase in Closing Costs above legal limit.

02/23/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Exempt from ATR

N/A

Yes

B

B

201395781

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.36490% or Final Disclosure APR of 8.36900% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-10): Exception was set as non-compliant HPML loan based on the second appraisal fee charged to the consumer. The lender has provided a refund to the consumer to remediate the second charge. Based on the refund being provided, this exception is regraded to EV2-B.

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201395781

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals.

Reviewer Comment (2017-03-10): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201395781

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.36490% or Final Disclosure APR of 8.36900% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201395781

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $11,128.45 and  Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $133,506.45.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201395781

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,039.00 exceeds tolerance of $1,750.00 plus 10% or $1,925.00.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-02-22): Lender provided $829.30 credit to borrower at closing.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201395781

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7507)

Reviewer Comment (2017-02-22): Lender provided $829.30 credit to borrower at closing.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201395781

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $30.30 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-02-22): Lender provided $829.30 credit to borrower at closing.

02/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201395781

Credit

Credit

Misc

Credit Exception:

Realtor credit used in transaction.

The residual income, $1,343, is above the required amount of $1,300. The reserves, 16 months, are in excess of program requirements of 3 months. The loan to value, 75%, is below the maximum required amount of 80%.

Reviewer Comment (2017-02-23): Client elects to waive.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201395781

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

The residual income, $1,343, is above the required amount of $1,300. The reserves, 16 months, are in excess of program requirements of 3 months. The loan to value, 75%, is below the maximum required amount of 80%.

Reviewer Comment (2017-02-23): Client elects to waive.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201398777

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

34 months reserves > 9 months guideline minimum

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201398777

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.06080% or Final Disclosure APR of 6.06100% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201398777

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.06080% or Final Disclosure APR of 6.06100% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201398777

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY]), but transaction consummation (mortgage notary) date was [MM/DD/YYYY]).   Data is still not accurate on subsequent CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201398777

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201398779

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-7,471.50  is less than amount of binding Lender Credit previously disclosed in the amount of $-7,472.00. (9300)

Reviewer Comment (2017-02-23): Erroneous Reg ID 3658.  LE was properly rounded.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201398779

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $966.90 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

Reviewer Comment (2017-02-23): Erroneous Reg ID 3060.  This fee was seller paid, and is customarily paid by Seller in the state of CA.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201398779

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201398779

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-02-23): The transfer tax  fee was seller paid, and is customarily paid by Seller in the state of CA.

02/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201398779

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID - Non Compliant.  Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure. Seller CD fees total $43,515.58 while Borrower's CD seller fees total $41593.15

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201398779

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

31 months reserves > 9 months guideline minimum

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201398785

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Guideline variance approved by lender at time of origination Compensating factors include: Residual income exceeds required $5,150, verified $8,097. PITI Resrves required-3 months, verified 30 months.

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201398785

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201398785

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Due to loan being non-warrantable condo the current DTI of 49.571 exceeds the max tolerance of 43%; Loan - meet SCFF requirements. Lender approved exception.

Guideline variance approved by lender at time of origination Compensating factors include: Residual income exceeds required $5,150, verified $8,097. PITI Resrves required-3 months, verified 30 months.

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201398785

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-02-27): All guideline violations have been addressed by client.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201398785

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-02-27): All guideline violations have been addressed by client.

02/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201400698

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

31% DTI on this full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2017-02-27): Client elects to waive.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201400698

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.27930% or Final Disclosure APR of 6.30700% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

HPML per lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201400698

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.27930% or Final Disclosure APR of 6.30700% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

HPML per lender's compliance testing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201400698

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan contains a Demand Feature. (Final/[MM/DD/YYYY])

Neither option is selected on the final CD.

Reviewer Comment (2017-02-27): This is cured on the[MM/DD/YYYY] post closing CD.

02/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201400698

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $65,128.54, final CD shows $74,862.38. Post closing [MM/DD/YYYY] CD shows $76,129.88.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201440253

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.17130% or Final Disclosure APR of 6.17100% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201440253

Compliance

Compliance

Federal Compliance

RESPA  -  Initial Escrow Account Statement Not Provided Timely

RESPA (2010): Initial escrow account statement was not provided to the borrower at closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201440253

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.17130% or Final Disclosure APR of 6.17100% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201440253

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201440253

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Borrower on this full documentation loan has a disposable income of $27,012.86 which exceeds minimum disposable income of $8,000, per Lender Exception. Per Lender Exception, DTI of 36.542%, max 43%.

Reviewer Comment (2017-03-06): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201483427

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

16 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-08): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/08/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201483427

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

Interest calculation is not for an even number of days, calculation is for 7.11 days, corrected on post-close disclosure

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201483427

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201483429

Credit

Loan Package Documentation

Closing / Title

Title: Evidence of title is missing

Title reports were not provided.

Reviewer Comment (2017-03-06): Received copy of title.

03/06/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201483429

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Residual income of $$6,671.41 is above the minimum required amount of $4,450 for an excess of $2,331.46. Reserves of 130 months are in excess of program minimum 3 months required. LTV of 80% is below program minimum of 90%. Housing Payment - Guidelines require a 24-month payment history and UW has verified 53 months history with [REDACTED]with no lates

Reviewer Comment (2017-03-13): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201483429

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201483429

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender maximum DTI is 50.00%, loan boarded at 56.95098%. Lender approved exception to 56.997% DTI

Residual income of $$6,671.41 is above the minimum required amount of $4,450 for an excess of $2,331.46. Reserves of 130 months are in excess of program minimum 3 months required. LTV of 80% is below program minimum of 90%. Housing Payment - Guidelines require a 24-month payment history and UW has verified 53 months history with [REDACTED]with no lates

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201483429

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-02): All guideline violations have been addressed by client.

03/02/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201483429

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-02): All guideline violations have been addressed by client.

03/02/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201483429

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title agent fees listed in section B and title agent not on SSPL, should be in section C.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201485416

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.43840% or Final Disclosure APR of 6.43800% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201485416

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.43840% or Final Disclosure APR of 6.43800% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201485416

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201485416

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual Income; Require $4,450; verified $11,800. Debt Ratio; Mazimum 43%; actual is 31%. Perfect rental history since 2010

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201485416

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender approved exception.

Residual Income; Require $4,450; verified $11,800. Debt Ratio; Mazimum 43%; actual is 31%. Perfect rental history since 2010

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201485416

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender approved exception.

Residual Income; Require $4,450; verified $11,800. Debt Ratio; Mazimum 43%; actual is 31%. Perfect rental history since 2010

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201485416

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,072.04 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Loan locked on[MM/DD/YYYY] at par and re-disclosed on[MM/DD/YYYY] with no discount points.  LE re-disclosed on[MM/DD/YYYY] has increased discount points and COC in file indicates lock updated with no valid COC provided for the increase, furthermore,, LE re-disclosed on[MM/DD/YYYY] has a even higher discount point fee with COC simply indicating FICO change; however; exception approval in file dated[MM/DD/YYYY] indicates the same FICO as the closed FICO and no other credit reports were found in the file.

Reviewer Comment (2017-04-06): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201485419

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Homeowner's Insurance Premium wasd disclosed as 12 months totalling $49,  however this would equate to $313.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201485419

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $150.00 exceeds tolerance of $100.00 plus 10% or $110.00.  Insufficient or no cure was provided to the borrower. (0)

$40 violation due to increase in recording fees.  Sufficient cure provided on final CD.

Reviewer Comment (2017-03-02): Cured at closing.

03/02/2017

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201485419

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee was not disclosed on initial Loan Estimate dated [MM/DD/YYYY]. Re-disclosed LE dated [MM/DD/YYYY] reflects fee was added without a valid change of circumstance. Lender is bound by Broker's LE unless a valid change of circumstance occurs. Refund due of $150.

Reviewer Comment (2017-03-08): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/08/2017

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201485419

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Fee was not disclosed on initial Loan Estimate dated [MM/DD/YYYY]. Re-disclosed LE dated [MM/DD/YYYY] reflects fee was added without a valid change of circumstance. Lender is bound by Broker's LE unless a vaid cahnge of circumstance occurs. Refund due of $150.

Reviewer Comment (2017-03-08): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/08/2017

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201485419

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender approved exception.

55.98% LTV < 80% LTV guideline max - 24.02% less than guidelines maximum 698 representative FICO score > 640 guideline minimum - 58 points above guideline minimum

Reviewer Comment (2017-03-02): Client elects to waive.

03/02/2017

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201485420

Credit

Loan Package Documentation

Closing / Title

Title: Evidence of title is missing

Reviewer Comment (2017-03-07): Received copy of final title policy.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201485420

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.69970% or Final Disclosure APR of 6.70000% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201485420

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.69970% or Final Disclosure APR of 6.70000% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201485420

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-03-07): Received evidence that borrower received disclosure within timing requirements.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201485420

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Final Closing Disclosure included seller's loan payoff

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201489293

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected put no report provided.

12 months reserves > 3 months required 80% LTV < max allowed of 90%

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201489293

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201489293

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

12 months reserves > 3 months required 80% LTV < max allowed of 90%

Reviewer Comment (2017-03-03): Client elects to waive.

03/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201489293

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-03): All guideline violations have been addressed by client.

03/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201489293

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-03): All guideline violations have been addressed by client.

03/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201489293

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201489293

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $801.90 exceeds tolerance of $794.00.  Insufficent or no cure was provided to the borrower. (8304)

Transfer tax increased on[MM/DD/YYYY] with initial CD ; however, the COC indicates only Courtesy re-disclosure which is not a valid COC for the increase in fees.

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201489295

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

718 representative FICO score > 660 guideline minimum - 58 points above guideline minimum

Reviewer Comment (2017-03-30): Client elects to waive.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201489295

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.58210% or Final Disclosure APR of 6.58200% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201489295

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,248.95 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Fee not disclosed on LE dated[MM/DD/YYYY] and on[MM/DD/YYYY].  Note: 2 disclosures in file dated[MM/DD/YYYY].  2nd disclosure reflects $1275 Discount points with COC indicating reason due to change inborrower's  FICO score, however no evidence of change in scores on credit reports found in the file.

Reviewer Comment (2017-04-17): Seller provided a post-close CD, copy of the refund check,  the letter of explanation sent to the borrower, and proof of delivery to cure the tolerance violation. Reviewer Comment (2017-03-30): Clarification on comments regarding violation:  On [MM/DD/YYYY] CD, there is a .25% discount fee.  On 2/17 CD, rate was extended.  Per CD, CoC and Rate Lock, there is no discount point.  However, on the final CD, issued [MM/DD/YYYY], there is now a .435% discount point.  The CoC gives no reason why it was added, there were no change in loan terms, and loan was already locked through [MM/DD/YYYY].

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201489295

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.58210% or Final Disclosure APR of 6.58200% is in excess of allowable threshold of APOR 3.55% + 2.5%, or 6.05000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201489295

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $2248.95.

Reviewer Comment (2017-04-17): Seller provided a post-close CD, proof of refund, letter of explanation and proof of delivery to cure the tolerance violation.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201489295

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,248.95 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7200)

Reviewer Comment (2017-04-17): Seller provided a post-close CD with a cure of $2,585.00.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201489298

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.61930% or Final Disclosure APR of 7.65300% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201489298

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.61930% or Final Disclosure APR of 7.65300% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

B

B

201489298

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Real Estate Commissions were not disclosed on Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201490026

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

It appears the lender used an index value that was not within the look back period per the Note.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201490026

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201490026

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7507)

cured by lender

Reviewer Comment (2017-03-07): Lender cured on the final CD with a $650 tolerance cure.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201490026

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

LTV is 75% when max LTV allowed is 80% 12 months reserves > 3 months guideline minimum Borrower has a disposable income of $14,175, in excess of minimum amount of $8,150

Reviewer Comment (2017-03-07): Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201490026

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-07): All guideline violations have been addressed by client.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201490026

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI fail - Lender approved exception

Reviewer Comment (2017-03-07): All guideline violations have been addressed by client.

03/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201490027

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.82870% or Final Disclosure APR of 6.82900% is in excess of allowable threshold of APOR 3.51% + 1.5%, or 5.01000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201490027

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.82870% or Final Disclosure APR of 6.82900% is in excess of allowable threshold of APOR 3.51% + 1.5%, or 5.01000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201490027

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Initial loan estimate used different format

Reviewer Comment (2017-03-06): Allowed on brokered loans.

03/06/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201490027

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2017-03-10): Received evidence that borrower received disclosure within timing requirements.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201490027

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $89.00 exceeds tolerance of $75.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Cured by kender

Reviewer Comment (2017-03-06): Cured at closing.

03/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201491263

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Significant excess residual income of $4586 per month DTI below required 43% (Caliber 50%)

Reviewer Comment (2017-03-07): Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201491263

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.39880% or Final Disclosure APR of 6.39900% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201491263

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.39880% or Final Disclosure APR of 6.39900% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201491263

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-03-08): Received evidence that borrower received disclosure within timing requirements.

03/08/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201491263

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201491263

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender Approved

Significant excess residual income of $4586 per month DTI below required 43% (Caliber 50%)

Reviewer Comment (2017-03-07): Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201491267

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.50400% or Final Disclosure APR of 6.50400% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201491267

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.50400% or Final Disclosure APR of 6.50400% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201491267

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201491267

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-3,180.00. (9300)

Reviewer Comment (2017-03-17): Received corrected CD with lender credit's previously listed on page moved to correct section on page 2.  Credit amount of $3175 was applied and VCC received showing that is the correct amount.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201491267

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $61.29 exceeds tolerance of $45.00.  Insufficent or no cure was provided to the borrower. (7520)

Cure provided on Closing Disclosure

Reviewer Comment (2017-03-07): Cured at closing.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201491267

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender Approved

Borrower on this loan has residual income of $21,803 > required $9,700 Below max DTI P&I payment being reduced approximately $1200 per month from $9,155 to $7,950

Reviewer Comment (2017-03-07): Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201491267

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender Approved

Borrower on this loan has residual income of $21,803 > required $9,700 Below max DTI P&I payment being reduced approximately $1200 per month from $9,155 to $7,950

Reviewer Comment (2017-03-07): Client elects to waive.

03/07/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201491267

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201491270

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

3 months reserves required, 20 months available. LTV of 80% below maximum of 85% Compensation or Income not in Effective Income: Borrower has a new part time position which started in September 2016, there is less than 2 yr history so it is not included BUT his annual salary for this job is $175,000 supported by a WVOE and Paystubs. It is considered a good compensating factor in allowing approval for both residual and dti exceptions to be allowed. Housing history 0x30x60 versus the 24 months required

Reviewer Comment (2017-03-10): Client elects to waive.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201491270

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.36160% or Final Disclosure APR of 6.36200% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Loan.

Note rate is 6.375%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201491270

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $16,384.16, final CD shows $930,402.43.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201491270

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

3 months reserves required, 20 months available. LTV of 80% below maximum of 85% Compensation or Income not in Effective Income: Borrower has a new part time position which started in September 2016, there is less than 2 yr history so it is not included BUT his annual salary for this job is $175,000 supported by a WVOE and Paystubs. It is considered a good compensating factor in allowing approval for both residual and dti exceptions to be allowed. Housing history 0x30x60 versus the 24 months required

Reviewer Comment (2017-03-10): Client elects to waive.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201491270

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.36160% or Final Disclosure APR of 6.36200% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Non-Compliant Higher Priced Mortgage Loan.

Note rate is 6.375%

Reviewer Comment (2017-03-10): All guideline violations have been addressed by client.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201491270

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-03-10): All guideline violations have been addressed by client.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201491270

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-10): All guideline violations have been addressed by client.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201491270

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-10): All guideline violations have been addressed by client.

03/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201491270

Credit

Credit

Misc

Credit Exception:

Residual income required $6,680, actual $6,320, short $360 in residual income.  Lender approved exception.

3 months reserves required, 20 months available. LTV of 80% below maximum of 85% Compensation or Income not in Effective Income: Borrower has a new part time position which started in September 2016, there is less than 2 yr history so it is not included BUT his annual salary for this job is $175,000 supported by a WVOE and Paystubs. It is considered a good compensating factor in allowing approval for both residual and dti exceptions to be allowed. Housing history 0x30x60 versus the 24 months required

Reviewer Comment (2017-03-10): Client elects to waive.

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201491270

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.36160% or Final Disclosure APR of 6.36200% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201491271

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved.

Borrower has residual income of $11,511.51 > required residual income of $6,450 42 months reserves > 6 months guideline minimum Max LTV on this program is 80% and current LTV is 70%

Reviewer Comment (2017-03-08): Client elects to waive.

03/08/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201491271

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $625, calculates to be $1440.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201491271

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,315.00. (9300)

LE dated[MM/DD/YYYY] reflects $1315 Lender Credit (Loan was locked) and Final CD reflects $0.00 Lender Credit.  Valid Changed Circumstance not found in file to justify this decreased Lender Credit.

Reviewer Comment (2017-03-17): Received corrected CD that moved the credit from page 3 to the correct section on page 2. Reviewer Comment (2017-03-16): Document uploaded did not address exception.

03/17/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201491271

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201491271

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Field Review Fee.  Fee Amount of $625.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower. (7508)

Reviewer Comment (2017-03-08): Cured at closing.

03/08/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201491271

Credit

Credit

Misc

Credit Exception:

Lender approved exception for allowing rental income used on subject property which is not allowed on the investment program.

Borrower has residual income of $11,511.51 > required residual income of $6,450 42 months reserves > 6 months guideline minimum Max LTV on this program is 80% and current LTV is 70%

Reviewer Comment (2017-03-08): Client elects to waive.

03/08/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201540248

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Second  valuation product was not provided.  Final CD reflects Field Review fee collected.

9 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201540248

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.82620% or Final Disclosure APR of 6.82700% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.25%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201540248

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.82620% or Final Disclosure APR of 6.82700% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Loan.

Note rate is 6.25%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201540248

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $24,172.87, final CD shows $1,120.87.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201540248

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

No

C

B

201540249

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

5% LTV exception to allow for 90% LTV when fico is below is below 680 (674). Loan is new construction app'd[MM/DD/YYYY]. Orig fico was 689 and dropped to 674 when credit repulled on[MM/DD/YYYY]. Exception approval is provided.

9 additional months PITIA reserves for subject (9 required, has 18) 0x30x24 when only 12 months required for HOA program.

Reviewer Comment (2017-03-09): Client elects to waive.

03/09/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201540249

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

9 additional months PITIA reserves for subject (9 required, has 18) 0x30x24 when only 12 months required for HOA program.

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201540249

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.73650% or Final Disclosure APR of 7.73700% is in excess of allowable threshold of APOR 4.14% + 1.5%, or 5.64000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.625%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201540249

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $3,892.31 exceeds tolerance of $3,831.00.  Insufficent or no cure was provided to the borrower. (8304)

The [MM/DD/YYYY], [MM/DD/YYYY] and [MM/DD/YYYY] redisclosed LE's identify they correct amount of $3,892 (rounded), but there is not valid changed circumstances documented in file.

Reviewer Comment (2017-03-16): Received VCC for change in fee.  Cure sufficient at closing.

03/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201540249

Credit

Credit

Misc

Credit Exception:

Lender used tax amount for vacant land of $810.12 annually ($67.51 mo). Title shows estimated taxes improved of $4,983.52 ($415.29 mo). Note: 1003, 1008 and AUS used the improved (415.29) amount for qualifying.

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).

03/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201540249

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title fees that borrower did shop for are identified in section B, these should be in section C.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201540249

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure of $.52)was reflected, which is insufficient to cure $61.31.

Reviewer Comment (2017-03-16): Received VCC for change in fee.  Cure sufficient at closing.

03/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201540249

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/149902)

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).

03/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201540249

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/149902)

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).

03/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201540253

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

60 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-14): Client elects to waive.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201540253

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.02550% or Final Disclosure APR of 7.02600% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 6.75%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201540253

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.02550% or Final Disclosure APR of 7.02600% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Loan.

Note rate is 6.75%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201540253

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-03-23): MDIA hardship waiver accepted for this timing requirement as well.

03/23/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201540253

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201540253

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing with Waiver

TILA-RESPA Integrated Disclosure:  Waiver of three (3) day waiting period for Closing Disclosure due to bona fide personal financial emergency. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-03-13): 3 day Waiver has been accepted.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201543146

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-500.00. (9300)

Reviewer Comment (2017-03-17): Lender credit moved from page 3 on final CD to correct page 2 on post close CD.  Credit amount sufficient.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201543146

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201543146

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

785 representative FICO score > 660 guideline minimum -125 points above guideline minimum

Reviewer Comment (2017-03-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543146

Credit

Loan Package Documentation

Closing / Title

Title: Evidence of title is missing

Reviewer Comment (2017-03-14): Received copy of title report.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201543150

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

40% DTI on this full documentation loan <50% guideline max - 10% below program guideline maximum

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543150

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.44400% or Final Disclosure APR of 7.44400% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201543150

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201543150

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201543150

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $855.00 exceeds tolerance of $710.00.  Insufficent or no cure was provided to the borrower. (73196)

Fee increased on re-disclosed LE dated[MM/DD/YYYY] with the COC indicating borrower requested product change which is not a valid COC for the increase in the fee, no further documentation provided for a valid COC.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201543150

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Processing Fee.  Fee Amount of $495.00 exceeds tolerance of $285.00.  Insufficent or no cure was provided to the borrower. (7334)

Fee increased on re-disclosed LE dated[MM/DD/YYYY] with the COC indicating borrower requested product change which is not a valid COC for the increase in the fee, no further documentation provided for a valid COC.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201543150

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee increased on re-disclosed LE dated[MM/DD/YYYY] with the COC indicating borrower requested product change which is not a valid COC for the increase in the fee, no further documentation provided for a valid COC.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201543152

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201543152

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception

Residual income of $11,649.21 when $8,000 is required. 29 months reserves only 3 required LTV of only 80% when borrower qualifies for 90%

Reviewer Comment (2017-03-13): Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543152

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-13): All guideline violations have been addressed by client.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201543152

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-13): All guideline violations have been addressed by client.

03/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201543152

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Residual income of $11,649.21 when $8,000 is required. 29 months reserves only 3 required LTV of only 80% when borrower qualifies for 90%

Reviewer Comment (2017-03-13): Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543153

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

38% DTI on this full documentation loan < 50% guideline max - 12% below program guideline maximum

Reviewer Comment (2017-03-16): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201543153

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.31270% or Final Disclosure APR of 6.31300% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201543153

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.31270% or Final Disclosure APR of 6.31300% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201543153

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $49.60 exceeds tolerance of $39.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-03-10): Lender cured on final CD with $10.60 tolerance cure,

03/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201543153

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201543156

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.17690% or Final Disclosure APR of 8.17700% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201543156

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender approved exception

Reserves; 85 months reserves available. Program requires 6 months. Residual Income; $1200/month required. Actual is $2137.72.

Reviewer Comment (2017-03-13): Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543156

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.17690% or Final Disclosure APR of 8.17700% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201543156

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Reserves; 85 months reserves available. Program requires 6 months. Residual Income; $1200/month required. Actual is $2137.72.

Reviewer Comment (2017-03-13): Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201543158

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

34% DTI on this full documentation loan < 50% guideline max - 16% below program guideline maximum

Reviewer Comment (2017-03-13): Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201543158

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.37790% or Final Disclosure APR of 6.35900% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201543158

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.37790% or Final Disclosure APR of 6.35900% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201543158

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

It appears the lender did not include the $1,445 Title - Escrow fee in the finance charge.

Reviewer Comment (2017-03-28): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2017-03-21): Received acknowledgement from lender that they did not include fee in FC calculations.  Received corrected CD.  Still missing LOE to borrower, copy of refund check, and proof of delivery.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201543158

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total of Payments that does not match the actual total of payments for the loan. (Final/[MM/DD/YYYY])

It appears the lender did not include the $1,445 Title - Escrow fee in the TOP.

Reviewer Comment (2017-03-21): Data correct on subsequent CDs (SFIG).

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201543158

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201556075

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.04310% or Final Disclosure APR of 6.04300% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201556075

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.04310% or Final Disclosure APR of 6.04300% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201556075

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201556075

Credit

Credit

Misc

Credit Exception:

Lender Apporved Exception:  To allow the use of commissions from sale of subject property as assets to be used towards the CTC as a credit from the buyers Real Estate Agent.  The amount of credit is $13,800 to be used towards closing costs.

Borrower on this full documentation loan has a disposable income of $6,917.07 39.755% DTI on this full documentation loan < 50.00% guideline max - 10.245% below program guideline maximum 737representative FICO score > 660 guideline minimum

Reviewer Comment (2017-03-15): Client elects to waive.

03/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201556075

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Closing, Loan Tie In and Notary fees reflected in section B, should be in section C, provider used is not listed on SSPL.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201556076

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

13 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-13): Client elects to waive.

03/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201556076

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.09400% or Final Disclosure APR of 7.09400% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201556076

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201556076

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.09400% or Final Disclosure APR of 7.09400% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201556077

Property

Property - Appraisal

General Appraisal Requirements

Valuation Exception:

Lender Approved Exception for allowing an  appraisal with only 4 comps when 6 are required for loan amounts over $625,000.

Borrower on this full documentation loan has a disposable income of $25,271.83 > $2,800.00 required

Reviewer Comment (2017-03-15): Client elects to waive.

03/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201556077

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $1298.15, calculates to be $1724.25.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201556077

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $974.25 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Fee not disclosed on CD dated[MM/DD/YYYY].  Note:  There are two disclosures dated[MM/DD/YYYY].

Reviewer Comment (2017-03-14): Final CD reflects $1298.15 Lender Credit for tolerance cure.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201556077

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee disclosed as $500 on LE dated[MM/DD/YYYY] and as $550 on Final CD.

Reviewer Comment (2017-03-14): Final CD reflects $1298.15 Lender Credit for tolerance cure.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201556077

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7507)

Fee not dfisclosed on LE dated[MM/DD/YYYY] and disclosed as $700 on Final CD.  Note:  COC issued for CD dated[MM/DD/YYYY] reflects $700 2nd appraisal fee, however Date Broker/Lender was notified was[MM/DD/YYYY] which is outside of time line requirements.

Reviewer Comment (2017-04-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2017-03-21): Lender stated that the violation was cured at closing.  However, the amount of the cure at closing was not sufficient for this violation.  The Cure amount of $1298.15 has already been applied to a $974.25 discount point violation and a $50 Appraisal Fee violation.  Cure is short by $426.10.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201556077

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $56,045.  Borrower's CD reflects $64,789.23.  ($54,965 paid at closing and $9,824.23 paid prior to closing)

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201564584

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The file is missing a copy of the Seller's CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201564584

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.50160% or Final Disclosure APR of 8.50200% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201564584

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

10 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201564587

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure [MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

The sellers CD has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

C

B

201564587

Compliance

Compliance

Federal Compliance

TRID non-compliant: Missing Seller's Closing Disclosure.

The sellers CD has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

C

B

201564587

Credit

Credit

Misc

Credit Exception:

Borrower income is mainly derived from rental income.  No lease agreements have been provided provided.  A lender exception has been approved to qualify the borrower calculating rental income on all properties as schedule C earnings.  Lender exception has been indexed in the document inventory, compensating factors have been added.

800 representative FICO score > 660 guideline minimum - 140 points above guideline minimum 27.89% DTI on this full/reduced with exception documentation loan < 43% guideline max - 15.11% below program guideline maximum 72 months reserves > 12 months guideline minimum

Reviewer Comment (2017-03-16): Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

No

C

B

201564587

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Evidence of a cure has not been provided.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

C

B

201564587

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search.  Fee Amount of $258.00 exceeds tolerance of $250.00.  Insufficent or no cure was provided to the borrower. (75178)

Title search was disclosed as $250.00 on the LE.  Actual charge to the borrower at closing was $258.00.  Evidence of a cure has not been provided.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/23/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

Yes

C

B

201564587

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $35.00 exceeds tolerance of $25.00.  Insufficent or no cure was provided to the borrower. (75197)

Recording service fee was disclosed as $25.00 on the LE.  Actual charge to the borrower at closing was $35.00.  Evidence of a cure has not been provided.

Reviewer Comment (2017-03-23): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/23/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

Yes

C

B

201564588

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-03-16): Received evidence that borrower received disclosure within timing requirements.

03/16/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201564588

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $595.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-03-14): Cured at closing.

03/14/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201564588

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Reviewer Comment (2017-03-26): Received copy of fraud report.

03/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201564588

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Payment Shock exceeds credit guidelines.

Payment shock of 338% exceeds maximum allowed of 250% for First Time Homebuyer.  Lender approved exception.

Residual income of $12,007 exceeds required of $5,150 Reserves of 11.33 months exceeds 9 required. DTI of 38.282% below maximum allowed of 50%

Reviewer Comment (2017-03-14): Client elects to waive.

03/14/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201564588

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.62480% or Final Disclosure APR of 6.63100% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201564591

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

26.8% DTI on this full documentation loan < 50% guideline max - 23.20% below program guideline maximum Borrower on this full documentation loan has a disposable income of $14,458.  Product requires residual of $4,300.

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201564591

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.59760% or Final Disclosure APR of 6.59800% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.  The loan is designated as higher priced.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201564591

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $8.56 exceeds tolerance of $8.00.  Insufficent or no cure was provided to the borrower. (7579)

Evidence of a cure was not provided.  Flood cert fee was disclosed as 8.00.  The actual charge at closing was $8.56.

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201564591

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $5,619.68 exceeds tolerance of $5,319.00.  Insufficent or no cure was provided to the borrower. (8304)

Evidence of a cure has not been provided.  Transfer taxes were disclosed on the LE as $5,319.00.  The actual charge to the borrower at closing was $5,619.68.

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201564591

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure [MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $10,619.17, while closing CD seller's fees total $-0-.

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201564591

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Interest

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed prepaid interest under Prepaids that does not match calculated figures. (Final/[MM/DD/YYYY])

Interest calculation disclosed on the final CD is 79.35 for 29 days totaling $2,386.41.  The amount of interest collected should be $2,301.15.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201564591

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Evidence of a cure has not been provided.  Transfer taxes and flood cert were under disclosed on the LE.  A lump sum lender credit in the amount of $2,115.96 was issued under adjustments in the summaries of transactions.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201564591

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Product requires 9 months reserves.  A lender exception was approved to allow the borrower to close with 4 months reserves.  Exception has been indexed, compensating factors have been added.

26.8% DTI on this full documentation loan < 50% guideline max - 23.20% below program guideline maximum Borrower on this full documentation loan has a disposable income of $14,458.  Product requires residual of $4,300.

Reviewer Comment (2017-03-15): Client elects to waive.

03/15/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201564592

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The sellers CD has not been provided in the loan documents.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201564592

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Reviewer Comment (2017-03-16): Cured at closing.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201564592

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Insufficent or no cure was provided to the borrower. (7580)

Reviewer Comment (2017-03-16): Cured at closing.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201564592

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.54360% or Final Disclosure APR of 7.54400% is in excess of allowable threshold of APOR 4.19% + 1.5%, or 5.69000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201564592

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

The upfront Homeowner's Insurance Premium was collected for 12 months totaling $261.07 which includes a 25.00 service fee, the monthly escrow payment is based on the annual premium of  $236.07 which does not include the service fee.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201564592

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Interim Closing Disclosure containing a change in APR, loan product or addition of prepayment penalty was not received by borrower at least three (3) business days prior to consummation.

The initial CD dated [MM/DD/YYYY] did not disclose an APR and there is no ackowledgement of receipt by the borrower at least 3 business days prior to consummation.

Reviewer Comment (2017-03-21): Received attestation that disclosure was produced by title and never presented to borrower.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201564592

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 3061.  The tax service and transfer tax fees were paid by the seller.  Evidence of an additional cure is not required.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201564592

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

36% DTI (29.312% calculated)  on this full documentation loan < 43% guideline max - 7% below program guideline maximum Borrower on this  full  documentation loan has a disposable income of $4,718. 24 months reserves > 12 months guideline minimum

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201564592

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

A lender exception was approved for the loan to value to exceed product guideline of 85% (reduced by 5% for non-warrantable condo level 3).  Exception has been indexed in the document inventory, compensating factors have been added.

36% DTI (29.312% calculated)  on this full documentation loan < 43% guideline max - 7% below program guideline maximum Borrower on this  full  documentation loan has a disposable income of $4,718. 24 months reserves > 12 months guideline minimum

Reviewer Comment (2017-03-16): Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201564592

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

1003 Error: Citizenship Source Documentation  was not provided

Per the initial and final 1003, borrower is not a U.S. Citizen nor a Permenant Resident Alien.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201564592

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

Borrower's E-Consent signed [MM/DD/YYYY] and the initial Loan Estimate was electroncially signed [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201564592

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

A lender exception has been approved for FICO score below the product required score of 700.  Exception has been indexed in the document inventory, compensating factors have been added.

36% DTI (29.312% calculated)  on this full documentation loan < 43% guideline max - 7% below program guideline maximum Borrower on this  full  documentation loan has a disposable income of $4,718. 24 months reserves > 12 months guideline minimum

Reviewer Comment (2017-03-16): Client elects to waive.

03/16/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201564593

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2017-03-23): Not required for Foreign Nationals.

03/23/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201564593

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $29,588.79, while closing CD seller's fees total $29,578.79.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201564593

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee was not disclosed on the initial Loan Estimate. Sufficient cure of $150 provided on the final CD.

Reviewer Comment (2017-03-16): Cured at closing.

03/16/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201564594

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD fees total $30,038.50, while closing CD seller's fees total $46,977.30.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201564594

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

42 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

03/23/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201588250

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

737 FICO > 660 required 16 months reserves > 3 months required.

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201588250

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.24660% or Final Disclosure APR of 6.24700% is in excess of allowable threshold of APOR 3.51% + 2.5%, or 6.01000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201588250

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201588250

Credit

Credit

Credit Eligibility

Guideline Issue:  Foreclosure timeline outside of credit guidelines

Short Sale seasoning from application date is < required 4 years, outside 4 years from Note date.  Lender approved exception.

737 FICO > 660 required 16 months reserves > 3 months required.

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201588250

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,105.00 exceeds tolerance of $985.00 plus 10% or $1,083.50.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-03-17): Cured at closing.

03/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201588250

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.24660% or Final Disclosure APR of 6.24700% is in excess of allowable threshold of APOR 3.51% + 2.5%, or 6.01000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201588251

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved Exception.

Borrower on this (Full) documentation loan has a disposable income of $4375.14. 16.12 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-15): Client elects to waive.

03/15/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201588251

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Borrower on this (Full) documentation loan has a disposable income of $4375.14. 16.12 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-21): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201588251

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-15): All guideline violations have been addressed by client.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201588251

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI > 50%.  Lender Approved.

Reviewer Comment (2017-03-15): All guideline violations have been addressed by client.

03/15/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201588251

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Settlement, E-Recording and Lender's Title Insurance fees reflected in section C, should be in section B.  Provider used is listed on SSPL.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201590298

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.27840% or Final Disclosure APR of 6.27800% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201590298

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.27840% or Final Disclosure APR of 6.27800% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201590298

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title - Notary Fees is listed in Section B: Services Borrower Did Not Shop For, however, borrower did not use the provider listed on the SPPL. This fee should have been in Section C: Services Borrower Did Shop For.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201590298

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

35% DTI on this full documentation loan < 50% guideline max - 15% below program guideline maximum

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201590299

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.03640% or Final Disclosure APR of 8.03600% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201590299

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.03640% or Final Disclosure APR of 8.03600% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201590299

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Final CD shows seller paid costs of $24978.30, Seller CD shows costs of $15334.79

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201590299

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

15 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201590301

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.18900% or Final Disclosure APR of 6.18900% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201590301

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $69,492.52.  Borrower's CD reflects $524,235.61.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201590301

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

28 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201590301

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY]), but transaction consummation (mortgage notary) date was [MM/DD/YYYY]).  Data is still not accurate on subsequent CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201590301

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.18900% or Final Disclosure APR of 6.18900% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201590302

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Unable to run compliance testing without note.

Reviewer Comment (2017-03-23): Received copy of note.

03/23/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

D

A

D

A

D

A

D

A

D

A

Non QM

Non QM

No

D

B

201590302

Credit

Loan Package Documentation

Closing / Title

Title: Evidence of title is missing

Reviewer Comment (2017-03-23): Received copy of title.

03/23/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

D

B

201590302

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.02320% or Final Disclosure APR of 6.02300% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

D

B

201590302

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.02320% or Final Disclosure APR of 6.02300% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

D

B

201590302

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201590302

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

D

B

201590302

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on [MM/DD/YYYY], prior to three (3) business days from transaction date of [MM/DD/YYYY].

Reviewer Comment (2017-03-29): Data correct on subsequent CDs (SFIG). Reviewer Comment (2017-03-23): While the consummation date is [MM/DD/YYYY], the CD issued on [MM/DD/YYYY] and signed on [MM/DD/YYYY] reflects a disbursement date of [MM/DD/YYYY]. Seller Comment (2017-03-23): After reviewing the given exception, it is concluded that considering the Consummation Date is [MM/DD/YYYY] and the Rescission End date fell on [MM/DD/YYYY]. The next day is confirmed to be the Funding Date as of [MM/DD/YYYY]. As proof of all related dates please see the LOS Screen shot noted below.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

D

B

201590304

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

39 months reserves > 6 months guideline minimum

Reviewer Comment (2017-04-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201590304

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.90470% or Final Disclosure APR of 7.90500% is in excess of allowable threshold of APOR 4.19% + 1.5%, or 5.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201590304

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the 10% tolerance issues.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201590304

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $11,650.00 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $12,600.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201590304

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,275.00 exceeds tolerance of $1,010.00 plus 10% or $1,111.00.  Insufficient or no cure was provided to the borrower. (0)

Title - Lender's Title Insurance was shown as $150 on LE and $428 on CD.

Reviewer Comment (2017-04-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201590304

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title - Closing Protection Letter and Title - Title Examination fees are listed in Section B: Services Borrower Did Not Shop For. Borrower did not use a provider listed on the SPPL for these fees. These fees should have been in Section C: Services Borrower Did Shop For.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201600750

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Missing page one of Note.

Reviewer Comment (2017-03-21): Received copy of full note.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

D

A

D

A

D

A

D

A

D

A

Higher Priced QM

Higher Priced QM

No

D

B

201600750

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

31.4% DTI on this Full documentation loan < 43% guideline max -11.6% below program guideline maximum 82 months reserves >9 months guideline minimum

Reviewer Comment (2017-03-23): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

D

B

201600750

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.25170% or Final Disclosure APR of 6.25900% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

D

B

201600750

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final Closing Disclosure reflects a closing date of [MM/DD/YYYY]; Mortgage notary date is [MM/DD/YYYY], page one of Note is missing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201600750

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

D

B

201600750

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Certification Fee.  Fee Amount of $145.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7517)

Final Closing Disclosure reflects a cost to cure of $979.80.

Reviewer Comment (2017-03-17): Lender provided $979.80 credit at closing for increase in Closing Costs above legal limit.

03/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

D

B

201600750

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

31.4% DTI on this Full documentation loan < 43% guideline max -11.6% below program guideline maximum 82 months reserves >9 months guideline minimum

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

D

B

201600751

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

51.99181% DTI exceeds program maximum of 50.00%. Lender approval of exception was provided for up to 55%..

Residual Income: Required $4,450.00 Actual $6,645.47 Difference $2,195.347 26 months. Not all are verified yet. Need 9 months. Using B2 income for [REDACTED] she was W2'ed (2014) then went 100 and schedule C (2015) averaged these 2 years. Used this amount. But in 2016 large increase in 1099 income $25,855 if used 2016 with a 5% reduction for expenses and 2015 schedule C would have $1,065.50 instead of just $537.15. This would lower the DTI. Mortgage Payment History: Have 47 months of satisfactory payment for primary residence. 12 months required.

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201600751

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Residual Income: Required $4,450.00 Actual $6,645.47 Difference $2,195.347 26 months. Not all are verified yet. Need 9 months. Using B2 income for [REDACTED] she was W2'ed (2014) then went 100 and schedule C (2015) averaged these 2 years. Used this amount. But in 2016 large increase in 1099 income $25,855 if used 2016 with a 5% reduction for expenses and 2015 schedule C would have $1,065.50 instead of just $537.15. This would lower the DTI. Mortgage Payment History: Have 47 months of satisfactory payment for primary residence. 12 months required.

Reviewer Comment (2017-03-17): Client elects to waive.

03/17/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201600751

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-17): All guideline violations have been addressed by client.

03/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201600751

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI > 50%.  Lender Approved

Reviewer Comment (2017-03-17): All guideline violations have been addressed by client.

03/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201600751

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $43,008.74, final CD shows $48,064.36.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201600752

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-03-22): Designation switched to Non-QM

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201600752

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $150, calculates to be $925

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201600752

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-775.00. (9300)

LE dated[MM/DD/YYYY] reflects $775 Lender Credit (loan was locked) and Final CD reflects $0.00.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.

Reviewer Comment (2017-04-11): Received VCC for rate lock extension.

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201600752

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $850.00 exceeds tolerance of $700.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2017-03-17): Final CD reflects $150 Lender Credit for tolerance cure.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201600752

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender Approved - FICO 618

Borrower on this Full documentation loan has a disposable income of $9123.19. Required $4200. 36.40%% DTI on this full documentation loan 50% guideline max

Reviewer Comment (2017-03-20): Client elects to waive.

03/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201600752

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Based on adjusted QM DTI of 43.553%.  QM qualification requires the use of the maximum rate in the first 5 years method.

Reviewer Comment (2017-03-22): Designation switched to Non-QM

03/22/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201600752

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

Fee collected but no report provided.

Borrower on this Full documentation loan has a disposable income of $9123.19. Required $4200. 36.40%% DTI on this full documentation loan 50% guideline max

Reviewer Comment (2017-04-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201600752

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.13750% or Final Disclosure APR of 7.13800% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201600752

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-03-22): Designation switched to Non-QM

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201609720

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

8 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-30): Client elects to waive.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201609720

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.08980% or Final Disclosure APR of 7.09000% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201609720

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.08980% or Final Disclosure APR of 7.09000% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201609720

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-03-17): Lender cured with post consummation CD dated[MM/DD/YYYY] issued the day of disbursement with the correct closing date of 3/6/2017.

03/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201609720

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Section F shows Homeowner's Insurance for 12 mo and premium of $901.09 or $75.09 per month. Section G shows monthly escrow for HOI of $81.92.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201609720

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on [MM/DD/YYYY], prior to three (3) business days from transaction date of [MM/DD/YYYY].

Reviewer Comment (2017-03-17): Lender provided a post consummation CD dated[MM/DD/YYYY], with a correct closing date of 3/6/2017 and disbursement date of[MM/DD/YYYY].

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201609720

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure found for zero% exception.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201609720

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $225.00 exceeds tolerance of $109.00 plus 10% or $119.90.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2017-03-17): Lender cured on post consummation CD dated[MM/DD/YYYY], the same day as disbursement with a $105.10 tolerance cure reflected.

03/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201609720

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Fee added on LE issued on [MM/DD/YYYY] but no valid change of circumstance in the file.

Reviewer Comment (2017-03-30): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201609721

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

720 representative FICO score >660 guideline minimum 74.07% < 80% maximum. Borrower on this (Full) documentation loan has a disposable income of $8,337.23 27 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-20): Client elects to waive.

03/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201609721

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.25820% or Final Disclosure APR of 6.25800% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Loan.

Verified fees were input correctly

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201609721

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, should be $2650.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201609721

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-4,000.00. (9300)

LE dated[MM/DD/YYYY] reflects $4000 Lender Credit (loan was locked) and Final CD reflects $1350 Lender paid fees.   Valid Changed Circumstance was not found in file to justify this decreased lender credit.  Note:  Lender also reflect a credit of $2650 for escrow taxes in payoffs and payments which would bring the total to $4000.

Reviewer Comment (2017-03-23): Lender credit moved from page 3 on final CD to correct page 2 on post close CD.  Credit amount sufficient.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201609721

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Lender Credit for Tax Escrows reflected in Payoffs and Payments should be in section J under Lender Credit.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201609721

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender Approved.

720 representative FICO score >660 guideline minimum 74.07% < 80% maximum. Borrower on this (Full) documentation loan has a disposable income of $8,337.23 27 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-20): Client elects to waive.

03/20/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201609721

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.25820% or Final Disclosure APR of 6.25800% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Non-Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

Reviewer Comment (2017-03-20): All guideline violations have been addressed by client.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201609721

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-03-20): All guideline violations have been addressed by client.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201609721

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-20): All guideline violations have been addressed by client.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201609721

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI > 50%, Lender Approved.

Reviewer Comment (2017-03-20): All guideline violations have been addressed by client.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201609721

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.25820% or Final Disclosure APR of 6.25800% is in excess of allowable threshold of APOR 3.45% + 2.5%, or 5.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

Non QM

Non QM

No

C

B

201609722

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

31 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-20): Client elects to waive.

03/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201609722

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201609722

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.19040% or Final Disclosure APR of 9.19000% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-26): SSI income added to DTI calcs.

03/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201609722

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The file is missing a copy of the Seller's CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201609722

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception up to 51%. DTI is 53.039%. Lender miscalculated property taxes. There is a 1099 in file to support borrower received Social Security Income, however the lender did not use this income to qualify.

Reviewer Comment (2017-03-26): SSI income added to calculations.  Borrower now within DTI requirements.

03/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201609722

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Lender approved exception up to 51%. DTI is 53.039%. Lender miscalculated property taxes. There is a 1099 in file to support borrower received Social Security Income, however the lender did not use this income to qualify.

Reviewer Comment (2017-03-26): SSI income added to DTI calcs.

03/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201609722

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Lender approved exception up to 51%. DTI is 53.039%. Lender miscalculated property taxes. There is a 1099 in file to support borrower received Social Security Income, however the lender did not use this income to qualify.

Reviewer Comment (2017-03-26): SSI income added to DTI calcs.

03/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201609722

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Lender approved exception up to 51%. DTI is 53.039%. Lender miscalculated property taxes. There is a 1099 in file to support borrower received Social Security Income, however the lender did not use this income to qualify.

Reviewer Comment (2017-03-26): SSI income added to DTI calcs.

03/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201609722

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.19040% or Final Disclosure APR of 9.19000% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201618107

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

411 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-20): Client elects to waive.

03/20/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201618107

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $500.00.  Insufficent or no cure was provided to the borrower. (7506)

Fee disclosed as $500 on LEs and as $600 on Final CD.

Reviewer Comment (2017-03-26): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

03/26/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201618107

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201618108

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

34 months reserves > 3 months guideline minimum

Reviewer Comment (2017-04-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201618108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (ProjSeq:1/156385)

Reviewer Comment (2017-04-03): Data correct on subsequent CDs (SFIG).

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201618108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/156386)

It appears the lender based the insurance escrow amount on $1,291.00 versus the actual $1,291.96.

Reviewer Comment (2017-04-03): Data correct on subsequent CDs (SFIG).

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201618108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/156387)

It appears the lender based the insurance escrow amount on $1,291.00 versus the actual $1,291.96.

Reviewer Comment (2017-04-03): Data correct on subsequent CDs (SFIG).

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201618108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/156388)

It appears the lender based the insurance escrow amount on $1,291.00 versus the actual $1,291.96.

Reviewer Comment (2017-04-03): Data correct on subsequent CDs (SFIG).

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201618108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/156385)

It appears the lender based the insurance escrow amount on $1,291.00 versus the actual $1,291.96.

Reviewer Comment (2017-04-03): Data correct on subsequent CDs (SFIG).

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201618108

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

It appears the lender based the insurance escrow amount on $1,291.00 versus the actual $1,291.96.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618108

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618108

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.02420% or Final Disclosure APR of 8.02400% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201618108

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Reviewer Comment (2017-03-26): Exception created in error.

03/26/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201618109

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

23 months reserves > 9 months guideline minimum

Reviewer Comment (2017-03-30): Received copy of check, corrected CD, proof of delivery and LOE to borrower.  Client elects to waive.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201618109

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.83050% or Final Disclosure APR of 6.83100% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201618109

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.83050% or Final Disclosure APR of 6.83100% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201618109

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final CD is signed on [MM/DD/YYYY], but discloses closing date as [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618109

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

All payment streams are incorrect due to incorrect monthly insurance amount used.  Insurance premium is $521.47 annual.  Correct monthly payment is $43.46.  Monthly payment amount incorrectly disclosed as $42.46.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618109

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Seller Credit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Seller Credit that does not match the Seller Credit from the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Seller credit was not disclosed in Cash to Close table.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618109

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618109

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-95.00. (9300)

Reviewer Comment (2017-03-29): Lender credit accurately entered on final CD.  No violation.

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201618109

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

HOA fees paid by Seller were not accurately disclosed causing discrepancy between final CD and Seller's CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618109

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,225.00 exceeds tolerance of $1,970.00 plus 10% or $2,167.00.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2017-03-29): Condo Questionnaire moved from 10% to 0% testing.  Removal of fee makes 10% testing within tolerance.

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201618109

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for HOA/Condo Questionnaire.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75215)

Reviewer Comment (2017-03-29): Cured at closing.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

Reviewer Comment (2017-04-19): PCCD, LOX was provided to the borrower and proof of delivery with Refund.

04/19/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $800.00 exceeds tolerance of $600.00.  Insufficent or no cure was provided to the borrower. (7506)

Cure provided on Closing Disclosure

Reviewer Comment (2017-03-20): Cured at closing.

03/20/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $135.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75206)

Fee listed in Section B but vendor is not on SSPL.

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/26/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Document Preparation Fee.  Fee Amount of $200.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7563)

Change of Circumstance not provided for this fee

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/26/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title fees are listed in Section B: Services Borrower Did Not Shop For, however, borrower did not use a provider listed on the SPPL for these fees. These fees should have been listed in Section C: Services Borrower Did Shop For.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Electronic Document Delivery Fee.  Fee Amount of $200.00 exceeds tolerance of $150.00.  Insufficent or no cure was provided to the borrower. (75188)

Fee listed in Section B but vendor is not on SSPL.

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/26/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Loan Tie-In Fee.  Fee Amount of $275.00 exceeds tolerance of $270.00.  Insufficent or no cure was provided to the borrower. (75190)

Fee listed in Section B but vendor is not on SSPL.

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/26/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Digital Archive Fee.  Fee Amount of $39.50 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7543)

Fee listed in Section B but vendor is not on SSPL.

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/26/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $250.00 exceeds tolerance of $100.00.  Insufficent or no cure was provided to the borrower. (7564)

Fee listed in Section B but vendor is not on SSPL.

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/26/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Lender's Title Insurance.  Fee Amount of $750.00 exceeds tolerance of $685.00.  Insufficent or no cure was provided to the borrower. (7567)

Fee listed in Section B but vendor is not on SSPL.

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/26/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618110

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Notary Fee.  Fee Amount of $250.00 exceeds tolerance of $200.00.  Insufficent or no cure was provided to the borrower. (7568)

Fee listed in Section B but vendor is not on SSPL.

Reviewer Comment (2017-03-26): Data correct on subsequent CDs (SFIG).  Fee moved to the correct section, C, and no longer subject to tolerance testing.

03/26/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201618111

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.40440% or Final Disclosure APR of 7.40400% is in excess of allowable threshold of APOR 4.20% + 2.5%, or 6.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201618111

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,350.00 exceeds tolerance of $875.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-03-21): Lender provided $2100 credit to borrower at closing.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201618111

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $1,625.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (7507)

Reviewer Comment (2017-03-21): Lender provided $2100 credit to borrower at closing.

03/21/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201618111

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

31% DTI on this full documentation loan < 50% guideline max - 19% below program guideline maximum

Reviewer Comment (2017-03-21): Client elects to waive.

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201618113

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

46% < required 50%

Reviewer Comment (2017-03-20): Client elects to waive.

03/20/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201618113

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.00130% or Final Disclosure APR of 9.00100% is in excess of allowable threshold of APOR 4.14% + 1.5%, or 5.64000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201618113

Compliance

Compliance

State Compliance

Connecticut HB5577 NP Threshold Test Fixed Loans

Connecticut Non-Prime Home Loan: APR on subject loan of 9.00130% or Final Disclosure APR of 9.00100% is in excess of allowable threshold of APOR 4.14% + 1.5%, or 5.64000%.  Compliant Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201618113

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero% tolerance issues.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618113

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $21,077.50 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $28,296.89.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618113

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $97.39 exceeds tolerance of $30.00.  Insufficent or no cure was provided to the borrower. (7520)

Even if paid be seller, credit reports are traditionally a buyer paid fee and need to be properly disclosed.

Reviewer Comment (2017-04-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Reviewer Comment (2017-03-28): Received LOE.  Missing corrected CD, proof of delivery and copy of refund check.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201618113

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title - Closing Protection Letter and Title - Lender Title Insurance are shown in Section B: Services Borrower Did Not Shop For. The borrower did not use a provider listed on the SPPL and these fees should have been in Section C: Services Borrower Did Shop For.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618113

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Closing Protection Letter Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7562)

Reviewer Comment (2017-04-03): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing. Reviewer Comment (2017-03-28): Received LOE.  Missing corrected CD, proof of delivery and copy of refund check.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201618114

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

19.20 months reserves > 6 months guideline minimum - borrowers have verified reserves of $60,213.95 31.62% DTI on this Full documentation loan < 43% guideline max - 11.38% below program guideline maximum

Reviewer Comment (2017-03-21): Client elects to waive.

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201618114

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.50150% or Final Disclosure APR of 6.50200% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201618114

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The file is missing a copy of the Seller's CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201618115

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $78,676.50 and Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing $79,990.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618115

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation.

192 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-21): Client elects to waive.

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201618116

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD shows $12,363.47, final CD shows $12,908.97.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618116

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing. (75106)

Reviewer Comment (2017-03-20): This was cured at closing.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201618116

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $43.61 exceeds tolerance of $25.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-03-20): This was cured at closing.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201618116

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $90.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-03-20): This was cured at closing.

03/20/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201618116

Compliance

Compliance

Federal Compliance

TRID non-compliant: Missing Seller's Closing Disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201618116

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.18240% or Final Disclosure APR of 7.18200% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

Note rate is 7.125%.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201618116

Credit

Credit

Misc

Credit Exception:

Missing borrower's seller's CD for investment property sold at [REDACTED]. Needed to support DTI and reserves.

Reviewer Comment (2017-03-29): Received document verifying sale and amount.

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201621704

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

44% DTI on this full documentation loan < 50% guideline max - 6% below program guideline maximum

Reviewer Comment (2017-03-21): Client elects to waive.

03/21/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201621704

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.87380% or Final Disclosure APR of 7.87400% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201621704

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $15,984.50.  Borrower's CD reflects $15,352.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201621704

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Closing Protection fee reflected in section B, should be in section C.  Provider used is not listed on SSPL.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201621705

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided,

34 months reserves > 3 months guideline minimum

Reviewer Comment (2017-04-03): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201621705

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201621705

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.26680% or Final Disclosure APR of 8.27400% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201621706

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-04-17): CDA was ordered and received supporting the Original Appraisal value. Reviewer Comment (2017-04-13): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201621706

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY]), but transaction consummation (mortgage notary) date was [MM/DD/YYYY]).

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201621706

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.02590% or Final Disclosure APR of 7.02600% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201621706

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $83.55.

Reviewer Comment (2017-04-06): Received VCC regarding borrower requested loan amount change.

04/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201621706

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,537.00 exceeds tolerance of $2,453.45.  Insufficent or no cure was provided to the borrower. (7200)

Fee disclosed as $2,453.45 on CD dated[MM/DD/YYYY] and as $2537 on Final CD.  Note: COC dated[MM/DD/YYYY] indicates a loan amount change from $245,345 to $255,000, however no reason was given for the increase.

Reviewer Comment (2017-04-06): Received VCC regarding borrower requested loan amount change.

04/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201621707

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.90060% or Final Disclosure APR of 6.90100% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Non-Compliant Higher Priced Mortgage Loan.

This exception will remain a 3 until the 0% tolerance violations are addressed.

Reviewer Comment (2017-04-03): Lender provided consumer with credit at closing to cover the second appraisal, regarded to EV2-B

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201621707

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals.

Reviewer Comment (2017-03-23): Cured at closing.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201621707

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201621707

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant:  Missing payee for Seller Mortgage Payoff.

Reviewer Comment (2017-04-03): Data correct on subsequent CDs (SFIG).

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201621707

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $450, calculates to be $1284.63.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201621707

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-449.00. (9300)

LE dated[MM/DD/YYYY]  reflects $449 Lender Credit (loan was locked) and Final CD reflects $0.00 Lender Credit.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.

Reviewer Comment (2017-04-03): Received VCC regarding borrower requesting lower interest rate.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201621707

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $299.63 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Fee not disclosed on LE dated[MM/DD/YYYY] and as $299.63 on Final CD.

Reviewer Comment (2017-04-03): Received VCC regarding borrower requesting lower interest rate.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201621707

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $450.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7507)

Reviewer Comment (2017-03-22): Final CD reflects $450 Lender Credit for tolerance cure.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201621707

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Desk review value not provided.

22 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-24): Client elects to waive.

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201621708

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

652 > required 620.

Reviewer Comment (2017-03-26): Client elects to waive.

03/26/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201621708

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.67790% or Final Disclosure APR of 7.70000% is in excess of allowable threshold of APOR 4.14% + 1.5%, or 5.64000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201621708

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $15, calculates to be $33.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201621708

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201621708

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $450.00 exceeds tolerance of $435.00.  Insufficent or no cure was provided to the borrower. (7506)

Reviewer Comment (2017-03-22): Final CD reflects $15 Lender Credit for tolerance cure.

03/22/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201627247

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $18,128.94.  Borrower's CD reflects $254,803.23.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201627247

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation.

645 > required 620

Reviewer Comment (2017-03-23): Client elects to waive.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201627247

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.12170% or Final Disclosure APR of 8.12200% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201627248

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.46470% or Final Disclosure APR of 8.46700% is in excess of allowable threshold of APOR 4.22% + 1.5%, or 5.72000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201627248

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Additional Property Taxes Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose number of months for Additional Property Taxes under Prepaids. (Final/[MM/DD/YYYY])

Data field is blank.  Data is still not accurate on subsequent disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201627248

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $100.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201627248

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

100 months reserves > 6 months guideline minimum

Reviewer Comment (2017-03-23): Client elects to waive.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201627248

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $100.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75197)

Fee not disclosed on LE.  Although the fee is seller paid, it is still included in tolerance testing.

Reviewer Comment (2017-04-11): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing. Reviewer Comment (2017-04-03): Still missing evidence that $100 recording fee paid by seller is for curing title. Reviewer Comment (2017-03-26): Received rebuttal stating that recording fees needed to cure title are a seller paid fee.  Please provide evidence that Recording Service Fee was for curing title and not for recording of notes, mortgages, deeds and financing statements.

04/11/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201627248

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant:  1).   AMC Fee reflected in section B, unable to determine type of fee from terminology used.  Note:  Data is still not accurate on subsequent CD.  2).  Missing payee for Electronic Recording Fee.  Note:  Fee was moved from section B to Section E on Subsequent disclosure with the name of the payee reflected.  No evidence of LOE in file.

Reviewer Comment (2017-04-03): Received payee for AMC fee and Electronic Recording Fee.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201627248

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $21,034.10.  Borrower's CD reflects $20,934.10.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201627249

Credit

Loan Package Documentation

Application / Processing

Missing Document: Flood Certificate not provided

Reviewer Comment (2017-04-06): Received copy of Flood Cert.

04/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201627249

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

21 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-24): Client elects to waive.

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201627249

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $47.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201627249

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $157.00 exceeds tolerance of $100.00 plus 10% or $110.00.  Insufficient or no cure was provided to the borrower. (0)

$47 tolerance violation.  Although Seller paid $57 of the fees, they are still included in tolerance testing.  Note:  It is customary in the state of NV for the seller to pay the recording of documents to remove encumbrances.  CD does not designate the type of fee this is.

Reviewer Comment (2017-04-13): Received all required documentation.  Seller paid fee removed from testing and no violation. Reviewer Comment (2017-04-04): Received updated post close CD.  Recording Fee total reduced to $113, $3 above tolerance.  Missing final settlement statement to validate the reduction in recording fees as well as evidence that seller paid fee is for moving encumbrances.  If not, then a $3 cure will be required.

04/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201627249

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.43890% or Final Disclosure APR of 6.43900% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201627249

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects 4,098.86.  Borrower's CD reflects $9,624.86.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201628246

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.66610% or Final Disclosure APR of 8.66600% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201628246

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Initial CD did not use Calculating Cash to Close without Seller

Reviewer Comment (2017-03-23): Data was corrected on subsequent disclosures

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201628246

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Borrower exceeds residual income requirements with excess month residual income = $196.70 per month 39.216% LTV < 80% guideline max

Reviewer Comment (2017-04-04): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201628246

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Debt service months discrepancy.

Lender Approved Exception

Borrower exceeds residual income requirements with excess month residual income = $196.70 per month 39.216% LTV < 80% guideline max

Reviewer Comment (2017-03-24): Client elects to waive.

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201628247

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

679 representative FICO score > 620 guideline minimum - 59 points above guideline minimum

Reviewer Comment (2017-04-04): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201628247

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.16810% or Final Disclosure APR of 7.17400% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201628247

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Closing Protection, Title Examination and Wire fees reflected in section B, should be in section C.  Providers used are not listed on SSPL.   Data is still not accurate on subsequent CD.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201628247

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $200.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201628247

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Examination Fee.  Fee Amount of $200.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7565)

Fee not disclosed on LE.

Reviewer Comment (2017-04-04): Received corrected CD with fees moved to correct section and no longer subject to tolerance testing.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201628248

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Non Primary Residence

TRID Final Closing Disclosure[MM/DD/YYYY] on a purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201628248

Compliance

Compliance

Federal Compliance

TRID non-compliant: Missing Seller's Closing Disclosure.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201628248

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $820.00 exceeds tolerance of $670.00 plus 10% or $737.00.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-03-24): Cured at closing.

03/24/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

N/A

N/A

Yes

C

B

201628248

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $600.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-03-24): Cured at closing.

03/24/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

N/A

N/A

Yes

C

B

201628248

Credit

Assets

Asset Calculation / Analysis

Guideline Requirement: Available for Reserves discrepancy.

Investment with Non-Warrantable Condo property requires 9 months on subject property plus 6 months for each additional financed property per Investment ARM and Fixed Program Summary. $16,568.64 (subject) + $23,656.80 (2 additional properties).

34.70% DTI on this (Full) documentation loan < 43% guideline max 721 representative FICO score > 620 guideline minimum Borrower on this (Full) documentation loan has a disposable income of $9,802.64

Reviewer Comment (2017-03-29): Client elects to waive.

03/29/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201628249

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

32 months reserves > 9 months guideline minimum

Reviewer Comment (2017-03-28): Client elects to waive.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201628249

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201628249

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $39.66 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7520)

Credit report fee not disclosed on loan estimate

Reviewer Comment (2017-03-28): Cured at closing.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201628249

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $620.40 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

Seller paid fee

Reviewer Comment (2017-03-28): Transfer tax is a seller paid fee.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201630658

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

92 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-29): Client elects to waive.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201630658

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.37530% or Final Disclosure APR of 8.37900% is in excess of allowable threshold of APOR 3.50% + 1.5%, or 5.00000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201630658

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure of 22.52 provided is sufficient to cure the under disclosure of the credit report and fees.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201630658

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $268.00 exceeds tolerance of $225.00 plus 10% or $247.50.  Insufficient or no cure was provided to the borrower. (0)

A cure of 22.52 was provided at closing which is sufficient to cure the under disclosure.

Reviewer Comment (2017-04-13): Cured at closing.

04/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201630658

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,384.66 exceeds tolerance of $2,206.70.  Insufficent or no cure was provided to the borrower. (7200)

CoC contained in file.  However, re-baselining fees on a CD is only allowed during 7 days prior to closing.  CoC is outside of that time frame.

Reviewer Comment (2017-04-13): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

04/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201630658

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $38.02 exceeds tolerance of $36.00.  Insufficent or no cure was provided to the borrower. (7520)

A cure of 22.52 was provided at closing which is sufficient to cure the under disclosure.

Reviewer Comment (2017-04-13): Cured at closing.

04/13/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201630658

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $1,932.74, while closing CD seller's fees total $371,458.00 which includes the sellers existing mortgage payoff.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201630659

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

No cure was found related to the zero tolerance issues.

Reviewer Comment (2017-04-17): Seller provided a valid change of circumstance disclosure for the LE issued [MM/DD/YYYY] satisfied the tolerance violation for the commitment fee.  The $100.00 tolerance violation for the Condo Questionnaire was provided on the final CD.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Higher Priced QM

Yes

C

B

201630659

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201630659

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for HOA/Condo Questionnaire.  Fee Amount of $100.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75215)

Reviewer Comment (2017-03-23): Lender cured on final CD with $100 tolerance cure.

03/23/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

Yes

C

B

201630659

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation.

32% DTI on this full documentation loan < 50% guideline max - 18% below program guideline maximum

Reviewer Comment (2017-03-24): Client elects to waive.

03/24/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Higher Priced QM

No

C

B

201630659

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Commitment Fee.  Fee Amount of $1,350.00 exceeds tolerance of $995.00.  Insufficent or no cure was provided to the borrower. (7368)

Lender COC in file indicates fee increased due to program change which is not a valid COC for increase in fees as it does meet the COC definition.

Reviewer Comment (2017-04-17): Seller provided a valid change of circumstance disclosure for the LE issued [MM/DD/YYYY].

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Higher Priced QM

Yes

C

B

201630659

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.13210% or Final Disclosure APR of 6.13200% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Higher Priced QM

No

C

B

201630659

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Higher Priced QM matches the Due Diligence Loan Designation of Higher Priced QM.

Reviewer Comment (2017-04-12): Designation switched to Rebuttable Presumption.

04/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Non QM

Higher Priced QM

Yes

C

B

201630661

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

DTI Exception approval provided Pg 188

71.00% LTV < 85.00 guideline max.   more equity than required by program guidelines Guideline variance approved by lender at time of origination.  Reserves 21 mo vs 3 mo required

Reviewer Comment (2017-03-27): Client elects to waive.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201630661

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

71.00% LTV < 85.00 guideline max.   more equity than required by program guidelines Guideline variance approved by lender at time of origination.  Reserves 21 mo vs 3 mo required

Reviewer Comment (2017-03-27): Client elects to waive.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201630661

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.35370% or Final Disclosure APR of 8.35400% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-27): All guideline violations have been addressed by client.

03/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201630661

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Exception approval provided Pg 188

Reviewer Comment (2017-03-27): All guideline violations have been addressed by client.

03/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201630661

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Exception approval provided Pg 188

Reviewer Comment (2017-03-27): All guideline violations have been addressed by client.

03/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201630661

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Exception approval provided Pg 188

Reviewer Comment (2017-03-27): All guideline violations have been addressed by client.

03/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201630661

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201630661

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.35370% or Final Disclosure APR of 8.35400% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201630662

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for Title - Electronic Document Delivery fee of $9.00 and Lender Credit of $168.00 was not provided. Total $177.00

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201630662

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-168.00. (9300)

Cure for Lender Credit of $168.00 was not provided.

Reviewer Comment (2017-04-11): Received corrected CD with fees moved to correct section.

04/11/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201630662

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201630662

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Electronic Document Delivery Fee.  Fee Amount of $9.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75188)

Cure for Title - Electronic Document Delivery fee of $9.00 was not provided.

Reviewer Comment (2017-04-18): Fee removed from 0% testing and moved to  10% testing. Reviewer Comment (2017-04-11): Per SSPL, This was not a fee that borrower was allowed to shop for, however fee was moved to Section C.

04/18/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201630662

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Guideline variance approved by lender at time of origination. Required income $1,000; verified $4,746.50; excess of $3,746.50. Number of months verified reserves: $107,094 - $26,435 CTC = $80,659 / $1,575.0 =  of 51.19 months in post closing reserves.

Reviewer Comment (2017-04-07): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/07/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201630662

Credit

Credit

Misc

Credit Exception:

Borrower is a First Time Home Buyer purchasing a second home. Lender approved the exception.

Guideline variance approved by lender at time of origination. Required income $1,000; verified $4,746.50; excess of $3,746.50. Number of months verified reserves: $107,094 - $26,435 CTC = $80,659 / $1,575.0 =  of 51.19 months in post closing reserves.

Reviewer Comment (2017-03-24): Client elects to waive.

03/24/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201630663

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $56,548.33.  Borrower's CD reflects $891,076.74.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201630663

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-04-17): CDA was ordered and received supporting the Original Appraisal Value. Reviewer Comment (2017-04-11): Received refund for CDA fee charged at closing.

04/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201630664

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

16.93% DTI on this full documentation loan < 50% guideline max - 33.07% below program guideline maximum Borrower on this full documentation loan has a disposable income of $10,687.

Reviewer Comment (2017-03-27): Client elects to waive.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201630664

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.92510% or Final Disclosure APR of 7.92500% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

The loan is designated as Higher Priced.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201630664

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75103)

A lender credit in the amount of $150.00 was issued at closing.  This is sufficient to cure the under disclosure.

Reviewer Comment (2017-03-27): Cured at closing.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201630664

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

A lender credit in the amount of $150.00 was issued at closing.  This is sufficient to cure the under disclosure.

Reviewer Comment (2017-03-27): Cured at closing.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201630664

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $22,353.90, while closing CD seller's fees total $18,027.94.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201630665

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.71670% or Final Disclosure APR of 7.71700% is in excess of allowable threshold of APOR 4.14% + 1.5%, or 5.64000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201630665

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller CD reflects $15,291.55.  Borrower's CD reflects $178,522.41.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201630665

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $44.04 exceeds tolerance of $25.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-03-27): cured at closing.

03/27/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201630665

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation.

37% DTI on this full documentation loan < 50% guideline max - 13% below program guideline maximum

Reviewer Comment (2017-03-27): Client elects to waive.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201630666

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

B

B

201630666

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on [MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Debt Consolidation

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

B

B

201630668

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-04-17): CDA was ordered and received supporting the original appraisal value. Reviewer Comment (2017-04-11): Received evidence of refund for CDA fee charged at closing.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201630668

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.31330% or Final Disclosure APR of 6.32100% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201630668

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

The file is missing a copy of the Seller's CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201630669

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $18, calculates to be $119.60.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201630669

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $57,138.08.  Borrower's CD reflects $878,343.07.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201630669

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $53.00 exceeds tolerance of $35.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-03-27): Final CD reflects $18 Lender credit for tolerance cure.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201630669

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $101.60 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (8304)

Fee not disclosed on LE.  Although the Fee is designated as Seller's City/County Tax Fee paid by the Seller, it is included in tolerance testing when reflected in section E.  Unable to determine from purchase contract who is responsible for fee.

Reviewer Comment (2017-04-11): Received evidence that fee was actually a Utility Bill owed to the city, not a transfer tax.

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201630669

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.61060% or Final Disclosure APR of 6.61100% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201630670

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-04-03): Received evidence that borrower received disclosure within timing requirements.

04/03/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201630670

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $800.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-03-27): Lender provided $350 credit to borrower at closing.

03/27/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201630670

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Residual Income in excess of required by $2470.57 25 months reserves over 24 months 0X30 mortgage history

Reviewer Comment (2017-04-07): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/07/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201630670

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

Residual Income in excess of required by $2470.57 25 months reserves over 24 months 0X30 mortgage history

Reviewer Comment (2017-03-28): Client elects to waive.

03/28/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201630670

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201630670

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201635239

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

12 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-27): Client elects to waive.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201635239

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.98010% or Final Disclosure APR of 6.98000% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201635239

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow -  Initial Escrow Payment

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed the Initial Escrow Payment that does not match the escrow payment disclosed on page 2. (Final/[MM/DD/YYYY])

Missing page 3 & 4 of the final CD.

Reviewer Comment (2017-04-03): Received full copy of CD.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201635239

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow -  Monthly Escrow Payment

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed the Monthly Escrow Payment that does not match the actual escrow payment for the loan. (Final/[MM/DD/YYYY])

Missing page 3 & 4 of the final CD.

Reviewer Comment (2017-04-03): Received full copy of CD.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201635239

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Borrower Paid Cash to Close

TILA-RESPA Integrated Disclosure - Costs at Closing: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed Cash to Close in the Costs at Closing Table that does not match the Calculating Cash to Close table. (Final/[MM/DD/YYYY])

Missing page 3 & 4 of the final CD.

Reviewer Comment (2017-04-03): Received full copy of CD.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201635239

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Value - Total Closing Costs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed the Final value of Total Closing Costs that does not match the Total Closing Costs (Borrower-Paid) from page 2. (Final/[MM/DD/YYYY])

Missing page 3 & 4 of the final CD.

Reviewer Comment (2017-04-03): Received full copy of CD.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201635239

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201635239

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Final closing disclosure dated[MM/DD/YYYY] missing pages 3 and 4.

Reviewer Comment (2017-04-03): Received full copy of CD.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201635239

Compliance

Compliance

Federal Compliance

TRID non-compliant:  There is a partially completed TRID disclosure in file, which is insufficient to complete testing.

Partially completed CD with no issue date and Closing date of[MM/DD/YYYY] in file.

Reviewer Comment (2017-04-03): Received attestation that disclosure was produced by title and never presented to borrower.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Disclosure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201635240

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

A lender exception has been approved to allow DTI to 55% as the borrower has met the minimum numerical credit factors for Tier 1 exception / approval as well as two of the specified credit factors (LTV, residual income).  Exception has been indexed in the document inventory, compensating factors have been added.

701 representative FICO score > 660 guideline minimum - 41 points above guideline minimum Borrower on this full documentation loan has a disposable income of $11,890.

Reviewer Comment (2017-03-28): Client elects to waive.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201635240

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.21420% or Final Disclosure APR of 6.21600% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Non-Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201635240

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

The E-Consent Disclosure was signed by the borrower on [MM/DD/YYYY], however the initial LE was electroncially signed [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201635240

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

A lender exception has been approved to allow DTI to 55% as the borrower has met the minimum numerical credit factors for Tier 1 exception / approval as well as two of the specified credit factors (LTV, residual income).  Exception has been indexed in the document inventory, compensating factors have been added.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201635240

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

A lender exception has been approved to allow DTI to 55% as the borrower has met the minimum numerical credit factors for Tier 1 exception / approval as well as two of the specified credit factors (LTV, residual income).  Exception has been indexed in the document inventory, compensating factors have been added.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201635240

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

A lender exception has been approved to allow DTI to 55% as the borrower has met the minimum numerical credit factors for Tier 1 exception / approval as well as two of the specified credit factors (LTV, residual income).  Exception has been indexed in the document inventory, compensating factors have been added.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201635240

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total of Payments that does not match the actual total of payments for the loan. (Final/[MM/DD/YYYY])

The TOP disclosed on the final CD is $2,562,890.30 while the calculated TOP is $2,563,090.30.  All fees have been verified as entered from the final CD on page 176 which includes an additional fee of $200.00 for the appraisal.

Reviewer Comment (2017-04-18): Letter of Explanation, Proof of Delivery, and Corrected CD was provided to the borrower.  LOX was resent  clarifying the purpose for the re disclosed CD. Reviewer Comment (2017-04-17): Seller provided a copy of the post-close CD dated [MM/DD/YYYY] with the corrected TOP; however the LOE sent to the borrower did not disclose the changes made to the TOP.  Provide a copy of the LOE sent to the borrower disclosing the changes made on the PCCD.  Condition remains Reviewer Comment (2017-04-11): Received LOE that CD has been revised to reflect correct TOP.  However, no corrected CD was provided.

04/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201635240

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.21420% or Final Disclosure APR of 6.21600% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201635241

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-29): Designation switched to Non-QM

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201635241

Compliance

Compliance

Federal Compliance

QM DTI

Qualified Mortgage (Dodd-Frank 2014): Total Debt to Income Ratio exceeds 43% and the images do not provide evidence loan is eligible for purchase, guarantee or insurance by the appropriate agency.

Reviewer Comment (2017-03-29): Designation switched to Non-QM

03/29/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201635241

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 7.40090% or Final Disclosure APR of 7.42200% is in excess of allowable threshold of APOR 4.23% + 2.5%, or 6.73000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

No

C

B

201635241

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Finance Charge that does not match the actual finance charge for the loan. (Final/[MM/DD/YYYY])

The Final Closing Disclosure reflects a Finance Charge of $1,059,104.95; however calculated Finance Charge is $1,059,229.95.  There is a $400 Transaction Coordination Fee that is payable to an Escrow Company by the buyer at closing that does not appear to be included in the finance charge and their is no valid evidence for it's exclusion found in the file.

Reviewer Comment (2017-04-13): Received attestation that Fee reflected in Section H is a Real Estate Transaction fee and not a title required fee.

04/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201635241

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Seller paid fees are missing from Borrower's final CD; however, a subsequent CD dated [MM/DD/YYYY] is in the file reflecting all Seller paid fees per the Seller CD but the required letter of explanation to Borrower was not found.

Reviewer Comment (2017-04-17): Seller provided a copy of the LOE sent to the borrower disclosing the changes made on the PCCD.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

Yes

C

B

201635241

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

Residual income of $9,546 which is above required amount of $6,680. Reserves of 11.31 months in excess of program requirements of 9X months. Co-borrower started receiving commission income on 04/2016 but has less than 1 year history of receipt. Compensation factor only. Commission income earned from 04/2016 is $490,190.97/12=$40,849/month. Borrower changed to new position within the same company and still receives salary along with the commission income. Ratios with commission income would be 22%.

Reviewer Comment (2017-03-28): Client elects to waive.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201635241

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.40090% or Final Disclosure APR of 7.42200% is in excess of allowable threshold of APOR 4.23% + 2.5%, or 6.73000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201635241

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201635241

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-28): All guideline violations have been addressed by client.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201635241

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.40090% or Final Disclosure APR of 7.42200% is in excess of allowable threshold of APOR 4.23% + 2.5%, or 6.73000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201635241

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Designation switched to Non-QM

Reviewer Comment (2017-03-29): Designation switched to Non-QM

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201635243

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Post consummation CD dated[MM/DD/YYYY] still reflects lower amount of Seller paid fees versus Seller CD.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

B

B

201635243

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-03-28): Cured at closing.

03/28/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

N/A

Yes

B

B

201635244

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

36.16% DTI on this Full  documentation loan < 50% guideline max - 13.84% below program guideline maximum 696 representative FICO score > 660 guideline minimum -36 points above guideline minimum

Reviewer Comment (2017-03-28): Client elects to waive.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201635244

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.92470% or Final Disclosure APR of 6.92500% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201635244

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY]), but transaction consummation (mortgage notary) date was [MM/DD/YYYY]).

Reviewer Comment (2017-04-13): New Final CD identified.  Exceptions reset.

04/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201635244

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 2933.  No violation of transfer fee.  This fee seller paid, and is customarily paid by Seller in the state of NV.

Reviewer Comment (2017-04-13): New Final CD identified.  Exceptions reset.

04/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201635244

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-13): New Final CD identified.  Exceptions reset.

04/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201635244

Credit

Credit

Misc

Credit Exception:

Lender Approved Procedural Exception for allowing realtor credits for closing costs indicates Investor guides do not prohibit and Caliber CPL guides to be updated will also allow.  Total credits of $1100 are within the 6% IPC guidelines.   No comp factors required.

36.16% DTI on this Full  documentation loan < 50% guideline max - 13.84% below program guideline maximum 696 representative FICO score > 660 guideline minimum -36 points above guideline minimum

Reviewer Comment (2017-03-28): Client elects to waive.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201635244

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Missing borrower's signatures on Final CD issued[MM/DD/YYYY].

Reviewer Comment (2017-04-13): Received verification that CD issued on 3/14 and signed on 3/16 is the final CD.  CD issued 3/16 is post close CD. Reviewer Comment (2017-04-03): Post close CD sent in.  Missing signed CD from closing.

04/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201635244

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-13): Data correct on subsequent CDs (SFIG).

04/13/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201635244

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201635244

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201635244

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Based on Final CD.

Reviewer Comment (2017-04-18): Re-Calc of reserves shows enough for guidelines.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201635245

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $100,811.14.  Borrower's CD reflects $62,536.14.,

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201635245

Credit

Credit

Misc

Credit Exception:

Lender Approved Exception:  Gifted Funds on a secondary residence purchase.

9.71 months reserves > 3 months guideline minimum. 68.327% LTV <80 guideline max.

Reviewer Comment (2017-03-28): Client elects to waive.

03/28/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201635246

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

19% DTI on this full documentation loan < 50% guideline max - 31% below program guideline maximum

Reviewer Comment (2017-04-07): Received copy of check, corrected CD, proof of delivery and LOE to borrower. Client elects to waive.

04/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201635246

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.15140% or Final Disclosure APR of 8.15100% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201635246

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 8.15140% or Final Disclosure APR of 8.15100% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201635246

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201635246

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $61.00 exceeds tolerance of $60.00.  Insufficent or no cure was provided to the borrower. (7520)

Fee disclosed as $60 on the LE dated , but disclosed as $61 on Final Closing Disclosure. Sufficient cure provided on final CD.

Reviewer Comment (2017-03-27): Lender cured on the final CD with a $1 tolerance cure.

03/27/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201635246

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

The E-Consent Disclosure was signed on [MM/DD/YYYY], however the initial LE was electroncially signed [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201639416

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

39.143% DTI on this loan < 43% guideline max Borrower on this loan has residual income of $11,636.96 > required $2,800

Reviewer Comment (2017-03-28): Client elects to waive.

03/28/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201639416

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.55870% or Final Disclosure APR of 6.55900% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201639416

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Actual Closing Date[MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201639416

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.55870% or Final Disclosure APR of 6.55900% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201639416

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

TRID Non-Compliant:  Missing payee for Seller's Notary Fee reflected in section H.

Reviewer Comment (2017-04-03): Data correct on subsequent CDs (SFIG).

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201639416

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $41,213.50.  Borrower's CD reflects $555,326.08

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201639416

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $121.05 exceeds tolerance of $100.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-03-28): Cured at closing.

03/28/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201639417

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Seller provided a valid change of circumstance disclosure dated [MM/DD/YYYY] disclosing the addition of the Collateral Desktop Fee.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201639417

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7367)

Reviewer Comment (2017-04-17): Seller provided a valid change of circumstance disclosure dated [MM/DD/YYYY] disclosing the addition of the Collateral Desktop Fee.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201639417

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2017-04-03): Received evidence that borrower received disclosure within timing requirements.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201639417

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.55840% or Final Disclosure APR of 8.64700% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201639417

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender approved exception.

Residual income of $3,731 exceeds required of $600 Reserves of 58.17 months exceeds required of 6 months.

Reviewer Comment (2017-03-29): Client elects to waive.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201639418

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.70830% or Final Disclosure APR of 6.78000% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201639418

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-04-03): Received evidence that borrower received disclosure within timing requirements.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201639418

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on [MM/DD/YYYY] reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section. (Final/[MM/DD/YYYY])

CD reflects Tax Service fee paid to the Lender.  No evidence found in file verifying this is a pass through fee.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201639418

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $83,488.52.  Borrower's CD reflects $89,191.64.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201639418

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

43% DTI on this full documentation loan < 50% guideline max - 7% below program guideline maximum

Reviewer Comment (2017-03-29): Client elects to waive.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201639418

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Reviewer Comment (2017-04-06): Fraud reports not required for review.

04/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201639419

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

VOR reflecting 6 years satisfactory payment history. Borrower on this (Full) documentation loan has a disposable income of $4,947.11

Reviewer Comment (2017-03-29): Client elects to waive.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201639419

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $11.25.

Reviewer Comment (2017-04-17): Seller provided a post-close CD, copy of the refund check for $2.25, a LOE to the borrower and proof of delivery to cure the tolerance violation.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201639419

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201639419

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $251.25 exceeds tolerance of $249.00.  Insufficent or no cure was provided to the borrower. (7564)

Fee disclosed as $249 on LE dated[MM/DD/YYYY] and as $251.25 on Final CD.  Note:  Fee was paid to Lender Affiliate thus tested under the zero percent tolerance regulations.

Reviewer Comment (2017-04-17): Seller provided a post-close CD, copy of the refund check for $2.25, a LOE to the borrower and proof of delivery to cure the tolerance violation.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201639419

Credit

Credit

Misc

Credit Exception:

Lender Exception: To not use Non-Warrantable Condo Guidelines for DTI, LTV, Reserves and minimum FICO score. Used Homeowner Access Guidelines.

VOR reflecting 6 years satisfactory payment history. Borrower on this (Full) documentation loan has a disposable income of $4,947.11

Reviewer Comment (2017-03-29): Client elects to waive.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201639419

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

E-Recording Fee reflected in section B, should be in section C.  Provider used is not listed on SSPL.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201639419

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $9.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75197)

Fee not disclosed on LE.

Reviewer Comment (2017-04-17): Seller provided a post-close CD moving the fee to section C as the borrower shopped for the service and the provider was not on the SSPL.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201639419

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.95360% or Final Disclosure APR of 6.95400% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201639419

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $251.25 exceeds tolerance of $249.00.  Sufficient or excess cure was provided to the borrower. (7564)

Reviewer Comment (2017-04-17): Seller provided a post-close CD, copy of the refund check for $2.25, a LOE to the borrower and proof of delivery to cure the tolerance violation.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201639420

Credit

Credit

Credit Eligibility

Guideline Issue:  Foreclosure timeline outside of credit guidelines

Lender Approved:  Previous foreclosure < 2 yrs prior to Close vs 2 yrs minimum requirement per guidelines.

22% DTI on this Full documentation loan < 28% guideline max - 50% below program guideline maximum Borrower on this Full documentation loan has a disposable income of $14,000. Guideline require $1,650.

Reviewer Comment (2017-03-29): Client elects to waive.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201639420

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

22% DTI on this Full documentation loan < 28% guideline max - 50% below program guideline maximum Borrower on this Full documentation loan has a disposable income of $14,000. Guideline require $1,650.

Reviewer Comment (2017-03-29): Client elects to waive.

03/29/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201639420

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.67240% or Final Disclosure APR of 7.67200% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201639420

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201639421

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

43 months reserves > 3 months guideline minimum

Reviewer Comment (2017-03-30): Client elects to waive.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201639421

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2017-04-03): Received a copy of a fraud report.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201639421

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.90010% or Final Disclosure APR of 6.91800% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201639421

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Data is corrected on subsequent CD, however no evidence in file of the required Letter of Explanation.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201639422

Credit

Credit

Credit Documentation

Aged document: Credit Report is older than guidelines permit

Credit Report dated [MM/DD/YYYY].  Note date[MM/DD/YYYY].

Reviewer Comment (2017-04-11): Received copy of updated credit report. Reviewer Comment (2017-04-03): Received Alert Report.  Unsure of it's significance.

04/11/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

N/A

N/A

No

C

A

201639422

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $84.32 exceeds tolerance of $41.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-03-30): Cured at closing.

03/30/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

N/A

N/A

Yes

C

A

201640750

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

36% DTI < 50% maximum allowed 50 months reserves > 9 months required

Reviewer Comment (2017-03-30): Client elects to waive.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201640750

Credit

Credit

Credit Eligibility

Guideline Issue:  Foreclosure timeline outside of credit guidelines

Previous foreclosure/short sale, 3 years 11 months prior to application date vs 4 yrs minimum requirement per guidelines. Lender approved using closing date for seasoning as opposed to application date.

36% DTI < 50% maximum allowed 50 months reserves > 9 months required

Reviewer Comment (2017-03-30): Client elects to waive.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201640750

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.52930% or Final Disclosure APR of 6.52900% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

Note rate 6.875%

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201640750

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201640750

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

The seller's CD shows -$499 (review could only go as low a $0.00), final CD shows $15.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201640750

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $2,316.50 exceeds tolerance of $2,314.00.  Sufficient or excess cure was provided to the borrower at Closing. (8304)

Reviewer Comment (2017-03-30): Cured at closing.

03/30/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201640751

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

32% DTI on this full documentation loan < 50% guideline max - 18% below program guideline maximum

Reviewer Comment (2017-03-30): Client elects to waive.

03/30/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Non QM

No

C

B

201640751

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.11110% or Final Disclosure APR of 7.11100% is in excess of allowable threshold of APOR 3.64% + 1.5%, or 5.14000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Non QM

No

C

B

201640751

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-04-17): Seller provided proof of the updated loan designation. Reviewer Comment (2017-04-03): Document uploaded does not pertain to exception.  Note:  an SLE will not cure this exception.  Designation change will be required.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201640751

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201640751

Compliance

Compliance

Federal Compliance

QM Employment History - Current Job after Gap

Qualified Mortgage (Dodd-Frank 2014): Current Job History post-Gap with LOE, lacking 6 months on current job.

Reviewer Comment (2017-04-17): Seller provided proof of the updated loan designation. Reviewer Comment (2017-04-03): Document uploaded does not pertain to exception.  Note:  an SLE will not cure this exception.  Designation change will be required.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

No

C

B

201640751

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Seller provided a post-close CD, LOE, proof of delivery and a copy of the refund check of $100.00 to cure the violation.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201640751

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $850.00 exceeds tolerance of $750.00.  Insufficent or no cure was provided to the borrower. (7506)

COC in file indicates change in loan amount which is not a valid COC for an increase in appraisal fee.

Reviewer Comment (2017-04-17): Seller provided a post-close CD, LOE, proof of delivery and a copy of the refund check of $100.00 to cure the violation.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Non QM

Yes

C

B

201640751

Compliance

Compliance

Federal Compliance

Check Restated Loan Designation Match - QM / ATR

Ability to Repay / Qualified Mortgage (Dodd-Frank 2014): The initial Loan Designation provided did not match, however, the updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM.

Reviewer Comment (2017-04-18): updated Loan Designation of Non QM matches the Due Diligence Loan Designation of Non QM. Comment:

04/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201640751

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $850.00 exceeds tolerance of $750.00.  Sufficient or excess cure was provided to the borrower. (7506)

Reviewer Comment (2017-04-17): Seller provided a post-close CD, LOE, proof of delivery and a copy of the refund check of $100.00 to cure the violation.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Higher Priced QM

Non QM

Yes

C

B

201640752

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

N/A

Yes

D

B

201640752

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $855.00 exceeds tolerance of $585.00.  Insufficent or no cure was provided to the borrower. (73196)

Reviewer Comment (2017-04-07): Received VCC reflecting the fee increase due to change of program.

04/07/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

Yes

D

B

201640752

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Processing Fee.  Fee Amount of $495.00 exceeds tolerance of $410.00.  Insufficent or no cure was provided to the borrower. (7334)

Reviewer Comment (2017-04-07): Received VCC reflecting the fee increase due to change of program.

04/07/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

Yes

D

B

201640752

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (75106)

Reviewer Comment (2017-04-07): Received VCC reflecting the fee increase due to change of program.

04/07/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

Yes

D

B

201640752

Credit

Loan Package Documentation

Application / Processing

Missing Document: Purchase Agreement / Sales Contract not provided

For upcoming purchase.

Reviewer Comment (2017-04-18): Received verification of new purchase.

04/18/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

D

A

D

A

D

A

D

A

D

A

Non QM

N/A

No

D

B

201640752

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception; however, unable to determine an actual DTI due to missing proposed payment on proposed primary.

Residual income of $8,573 exceeds the required of $1,400 Reserves of 191 months exceeds the required 9 for subject and 6 for other financed properties. LTV of 67% well below maximum allowed of 80%

Reviewer Comment (2017-04-18): Client elects to waive.

04/18/2017

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Non QM

N/A

No

D

B

201640752

Credit

Insurance

Insurance Documentation

Hazard Insurance Error: Missing HO-6 policy, blanket hazard insurance policy provided does not contain unit interior coverage.

Reviewer Comment (2017-04-03): Received copy of HO-6 Policy.

04/03/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

D

B

201640752

Credit

Credit

Misc

Credit Exception:

Borrowers were in process of purchasing a new primary residence (use of cash-out for subject) and the file does not contain any evidence of the proposed PITIA on the proposed residence.  Documents in submission show all currently owned properties as rentals so borrower's have no primary residence expenses.

Reviewer Comment (2017-04-18): Received verification of new purchase.

04/18/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

D

B

201640752

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - REO 25% Method

Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income (25% Method) using reasonably reliable third-party records. (Subject/25% Vacancy Method)

Missing lease for subject property.  Property has been rented for last 2 years but no lease provided.

Reviewer Comment (2017-04-18): Received copy of lease.

04/18/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

D

B

201640752

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Non QM

N/A

No

D

B

201640752

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Non QM

N/A

No

D

B

201641168

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

48.23 months reserves > 9 months guideline minimum - borrowers have verified reserves of $116,230.67 720 representative FICO score > 660 guideline minimum - 60 points above guideline minimum

Reviewer Comment (2017-03-31): Client elects to waive.

03/31/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641168

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2017-04-07): Guidelines to not require fraud report.

04/07/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641168

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Seller provided evidence that the appraisal was provided to the borrower within the required time.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201641168

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.35290% or Final Disclosure APR of 6.39400% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Non-Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

Reviewer Comment (2017-04-17): Seller provided evidence that the appraisal was provided to the borrower within the required time.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641168

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Seller provided evidence that the appraisal was provided to the borrower within the required time.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641168

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.35290% or Final Disclosure APR of 6.39400% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Non QM

Non QM

No

C

B

201641169

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated IRA distribution at $2083.33 versus Lender's $2500 and $1875.25 negative rent on subjsect property versus Lender's $1336.61.

Reviewer Comment (2017-04-13): Received verification that tax amount should be $344.49/month.  DTI now within guidelines. Reviewer Comment (2017-04-07): Received rebuttal stating that lender's IRA calculation amount has been corrected.  Reviewer corrected lease amount to $2300.  However, in lender's rental income calculations, they used $344.49 for taxes rather than the correct amount of $658.24.  Therefore, the DTI is 44.17% rather than 39.701%.

04/13/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

C

A

C

A

C

A

C

A

C

A

Exempt from ATR

N/A

No

C

B

201641169

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

C

B

201641169

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total of Payments that does not match the actual total of payments for the loan. (Final/[MM/DD/YYYY])

CD reflects $649,879.93, calculates to be $650,666.38.  A $786.45 variance.  It appears Lender did not want to includ the $786.45 payment reflected as settlement payment on CCD dated[MM/DD/YYYY] and as Do Not Use on final CD.

Reviewer Comment (2017-04-11): Data correct on subsequent CD.

04/11/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

C

B

C

B

Exempt from ATR

N/A

Yes

C

B

201641169

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $680.72.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

C

B

201641169

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

C

B

201641169

Credit

Credit

Misc

Credit Exception:

Lender approved exception to use rental income to qualify on a purchase.

70% < 80% max. 788 representative FICO score > 620 guideline minimu

Reviewer Comment (2017-03-31): Client elects to waive.

03/31/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Exempt from ATR

N/A

No

C

B

201641169

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,063.45 exceeds tolerance of $1,257.00 plus 10% or $1,382.70.  Insufficient or no cure was provided to the borrower. (0)

$680.75 tolerance violation due to the Do Not Use fee.

Reviewer Comment (2017-04-11): Received evidence that Do Not Use fee was actually a Settlement Fee.  Inclusion in 10% testing reflects to violation.

04/11/2017

1

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Exempt from ATR

N/A

Yes

C

B

201641170

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201641170

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $64.60 exceeds tolerance of $55.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-03-31): Lender cured on final CD with $9,60 tolerance cure.

03/31/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

N/A

N/A

Yes

C

B

201641170

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

Residual income of $6,000 is in excess of required $1,300 LTV of 80% below maximum allowed of 85% Reserves of 12 months in excess of required 6 months.

Reviewer Comment (2017-03-31): Client elects to waive.

03/31/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

N/A

N/A

No

C

B

201641170

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology and Order

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on[MM/DD/YYYY] did not use the same fee terminology or did not list the fees in the same sequential order as the Loan Estimate. (Final/[MM/DD/YYYY])

All LE's and initial CD reflect Title - Escrow Fee, final CD in file inaccurately describes as DO NOT USE.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

N/A

N/A

Yes

C

B

201641171

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation product was not provided.

44 months reserves > 3 months guideline minimum Verified residual income of $2,531, $2,200 guideline requirement.

Reviewer Comment (2017-03-31): Client elects to waive.

03/31/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641171

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Seller provided evidence that the appraisal was provided to the borrower.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

No

C

B

201641171

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.14240% or Final Disclosure APR of 9.14700% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-04-17): Seller provided evidence that the appraisal was provided to the borrower.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641171

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Seller provided evidence that the appraisal was provided to the borrower.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641171

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Change - Down Payment

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on [MM/DD/YYYY] incorrectly disclosed whether there was a change in the Down Payment/Funds from Borrower. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641171

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201641171

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Corrected on post close CD; however, explanation letter to the borrower was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641171

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception.

44 months reserves > 3 months guideline minimum Verified residual income of $2,531, $2,200 guideline requirement.

Reviewer Comment (2017-03-31): Client elects to waive.

03/31/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641171

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-03-31): All guideline violations have been addressed by client.

03/31/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641171

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-03-31): All guideline violations have been addressed by client.

03/31/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201641171

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-03-31): All guideline violations have been addressed by client.

03/31/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641171

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.14240% or Final Disclosure APR of 9.14700% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201641611

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641611

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception.

Residual income of $4,265.52 is above the minimum required amount of $2,750 for an excess of $1,515.52. Reserves of 83 months are in excess of program minimum of 9 months required.

Reviewer Comment (2017-04-03): Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641611

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.55140% or Final Disclosure APR of 6.55100% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201641611

Credit

Credit

Credit Eligibility

Guideline Issue:  Foreclosure timeline outside of credit guidelines

Previous foreclosure 1.17 yrs prior to Close vs 4 yrs minimum requirement per guidelines.  Per the guidelines, Foreclosure seasoning is from date of completion and if multiple significant derogatory events, accrual period will be based on the seasoning of the most recent.  Lender approved an exception allowing the foreclosure seasoning to be based on the Chapter 13 filing date since mortgage was included.

Residual income of $4,265.52 is above the minimum required amount of $2,750 for an excess of $1,515.52. Reserves of 83 months are in excess of program minimum of 9 months required.

Reviewer Comment (2017-04-03): Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641615

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

12 months reserves > 6 months guideline minimum

Reviewer Comment (2017-04-03): Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641615

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.25150% or Final Disclosure APR of 6.25200% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201641615

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.25150% or Final Disclosure APR of 6.25200% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201641615

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY]. Note:  Data was corrected on subsequent CD, however missing letter of explanation.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641615

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on[MM/DD/YYYY], prior to three (3) business days from transaction date of[MM/DD/YYYY].

Closing Disclosure reflects a Disbursement Date of [MM/DD/YYYY], but the Right to Cancel expiration date is [MM/DD/YYYY]. Note;  Data was corrected on subsequent disclosure, however missing letter of Explanation, Proof of Delivery, and verification Rescission was re-opended using the correct model form

Reviewer Comment (2017-04-17): Seller provided the PCCD, LOX, Proof of delivery to borrower.  Loan did not fund until 3/27 and therefore the disbursement date was after 3 business days from the closing date of 3/27. Reviewer Comment (2017-04-11): Received LOE that post close CD was issued.  This is acknowledged;  what's missing is LOE and proof of delivery or receipt.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201641616

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this (Documentation Type) documentation loan has a disposable income of $8100 Have 11 months reserves and 3 are required

Reviewer Comment (2017-04-03): Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641616

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.98080% or Final Disclosure APR of 6.98100% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201641616

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641616

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641616

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender Approved Exception

Borrower on this (Documentation Type) documentation loan has a disposable income of $8100 Have 11 months reserves and 3 are required

Reviewer Comment (2017-04-03): Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641616

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $132.96 exceeds tolerance of $100.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-04-03): Cured at closing.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201641616

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower on this (Documentation Type) documentation loan has a disposable income of $8100 Have 11 months reserves and 3 are required

Reviewer Comment (2017-04-03): Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641616

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.98080% or Final Disclosure APR of 6.98100% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-04-03): All guideline violations have been addressed by client.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641616

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-04-03): All guideline violations have been addressed by client.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641616

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-04-03): All guideline violations have been addressed by client.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201641616

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-04-03): All guideline violations have been addressed by client.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641616

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.98080% or Final Disclosure APR of 6.98100% is in excess of allowable threshold of APOR 3.48% + 2.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201641617

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

53 months reserves > 6 months guideline minimum

Reviewer Comment (2017-04-03): Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641617

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.76740% or Final Disclosure APR of 7.76700% is in excess of allowable threshold of APOR 3.60% + 2.5%, or 6.10000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201641617

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Disclosure reflects Closing Date of [MM/DD/YYYY], but transaction consummation (mortgage notary) date was [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641617

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $28,725.25, while closing CD seller's fees total $524,796.72.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641617

Credit

Loan Package Documentation

Application / Processing

Missing Document: Bankruptcy Documents not provided

Reviewer Comment (2017-04-07): Received copy of discharge.  BK documents are not required per guidelines.

04/07/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641618

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

683 representative FICO score > 620 guideline minimum Borrower on this (Full) documentation loan has a disposable income of $3,256.94

Reviewer Comment (2017-04-03): Client elects to waive.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641618

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $59.50 exceeds tolerance of $52.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Reviewer Comment (2017-04-03): Cured at closing.

04/03/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201641618

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $19,591.55.  Borrower's CD reflects $20,861.042.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641618

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

683 representative FICO score > 620 guideline minimum Borrower on this (Full) documentation loan has a disposable income of $3,256.94

Reviewer Comment (2017-04-18): Client elects to waive.

04/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641618

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.82590% or Final Disclosure APR of 7.82600% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Non-Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641618

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641618

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201641618

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI > 50%.  Lender approved increase in maximum to 55%.

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201641618

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.82590% or Final Disclosure APR of 7.82600% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201641760

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 9.29020% or Final Disclosure APR of 9.29000% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Loan.

verified fees were input correctly

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201641760

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Property Value

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an Appraised Property Value that did not match the actual Property Value for the loan. (Final/[MM/DD/YYYY])

Final CD in file reflects prior sales price used by lender in LTV calculation versus the appraised value.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641760

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on[MM/DD/YYYY], prior to three (3) business days from transaction date of[MM/DD/YYYY].

Data was corrected on Post Close CD, however missing LOE, proof of delivery and verification recission was re-opened using correct form.

Reviewer Comment (2017-04-04): Data correct on subsequent CDs (SFIG). Reviewer Comment (2017-04-04): Lender cured with post consummation CD dated[MM/DD/YYYY] issued prior to disbursement with a corrected disbursement date of[MM/DD/YYYY].

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201641760

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender approved an exception to allow the cash-out received from a rate/term delayed financing transaction.

Significant excess residual income of $4,581.65 a month, required is $1,650, verified at $6,231.65. DTI of 31% is well below 43% maximum allowed.

Reviewer Comment (2017-04-04): Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641760

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.29020% or Final Disclosure APR of 9.29000% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Mortgage Loan.

Verified feed were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201641760

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $620.00 exceeds tolerance of $615.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-04-04): Cured at closing.

04/04/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201641761

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Borrower on this (Full) documentation loan has a disposable income of $3,696.82, $1,300 minimum requirement. 59 months on time housing payment history for primary housing, 12 month minimum requiredment.

Reviewer Comment (2017-04-04): Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641761

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.16670% or Final Disclosure APR of 7.16700% is in excess of allowable threshold of APOR 3.64% + 1.5%, or 5.14000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201641761

Compliance

Compliance

State Compliance

(State HPML) Minnesota Subprime (APR Exceeds Subprime Threshold)

Minnesota Subprime Loan: APR on subject loan of 7.16670% or Final Disclosure APR of 7.16700% is in excess of allowable threshold of USTreasury 3.1100% + 3%, or 6.11000%.  Compliant Subprime Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201641761

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous Reg ID 2933.  No violation of transfer fee.  $724.20 of this fee was seller paid, and is customarily paid by Seller in the state of (MN.).

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641761

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $14,258.  Borrower's CD reflects $153,750.16.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641761

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,553.00 exceeds tolerance of $1,255.00 plus 10% or $1,380.50.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2017-04-03): Final CD reflecytds $172.50 Lender Credit for tolerance cure.

04/03/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201641761

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Lender Approved

Borrower on this (Full) documentation loan has a disposable income of $3,696.82, $1,300 minimum requirement. 59 months on time housing payment history for primary housing, 12 month minimum requiredment.

Reviewer Comment (2017-04-04): Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641762

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD data field is blank, calculates to be $35.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641762

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects $42,122.95.  Borrower's CD reflects $529,095.72.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201641762

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $200.00 exceeds tolerance of $150.00 plus 10% or $165.00.  Insufficient or no cure was provided to the borrower. (0)

$35 tolerance violation due to increase in recording fees.  Missing evidence that seller paid portion is not traditionally a buyer fee.

Reviewer Comment (2017-04-17): Received evidence that fee was for payoffs and not a buyer's fee. Reviewer Comment (2017-04-07): Received rebuttal that fee was seller paid.  This is understood.  Per exception, missing proof that recording fee paid by seller is not traditionally a buyer paid fee simply paid by the seller.  No evidence of what the recording fee was actually for.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201641762

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

20 months reserves > 3 months guideline minimum

Reviewer Comment (2017-04-04): Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201641762

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.38020% or Final Disclosure APR of 8.38300% is in excess of allowable threshold of APOR 3.60% + 2.5%, or 6.10000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643220

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

66.563% LTV <80% guideline max 35 months reserves > 3 months guideline minimum Borrower on this full documentation loan has a disposable income of $125%, 12 months reserves.

Reviewer Comment (2017-04-04): Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643220

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201643220

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

RICACO Comments in file indicate an exception  was approved to allow higher DTI; however, no exception found in the file.

66.563% LTV <80% guideline max 35 months reserves > 3 months guideline minimum Borrower on this full documentation loan has a disposable income of $125%, 12 months reserves.

Reviewer Comment (2017-04-17): Client elects to waive.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643220

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.57470% or Final Disclosure APR of 6.57500% is in excess of allowable threshold of APOR 3.60% + 1.5%, or 5.10000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-04-17): All guideline violations have been addressed by client.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643220

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-04-17): All guideline violations have been addressed by client.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643220

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-04-17): All guideline violations have been addressed by client.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201643220

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-04-17): All guideline violations have been addressed by client.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643220

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $125.75 exceeds tolerance of $35.00.  Sufficient or excess cure was provided to the borrower at Closing. (7520)

Lender provided $90.75 credit at closing for increase in Closing Costs above legal limit.

Reviewer Comment (2017-04-04): Cured at closing.

04/04/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201643220

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.57470% or Final Disclosure APR of 6.57500% is in excess of allowable threshold of APOR 3.60% + 1.5%, or 5.10000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

Non QM

Non QM

No

C

B

201643221

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-04-17): Seller provided evidence of the Refunded fee to the borrower.  CDA was ordered and received supporting original appraisal value.

04/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643221

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643221

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

Title - Lender Title Insurance is shown in section B: Services Borrower Did Not Shop For, however, borrower did not use a provider listed on the SPPL. This fee should have been in section C: Services Borrower Did Shop For.

Reviewer Comment (2017-04-17): Seller provided a refund to the borrower, and CDA was received supporting the appraisal value.

04/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

Good Faith Redisclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201643221

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Insufficient cure provided for zero and 10% tolerance issues.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643221

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,423.00 exceeds tolerance of $1,178.00 plus 10% or $1,295.80.  Sufficient or excess cure was provided to the borrower. (0)

Reviewer Comment (2017-04-04): Cured at closing.

04/04/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643221

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower. (7506)

Lender provided $150.00 credit at closing for increase in Closing Costs above legal limit.

Reviewer Comment (2017-04-04): Cured at closing.

04/04/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643223

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

10 months > required 6 months.

Reviewer Comment (2017-04-04): Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643223

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.41490% or Final Disclosure APR of 8.42300% is in excess of allowable threshold of APOR 3.45% + 1.5%, or 4.95000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643224

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.90800% or Final Disclosure APR of 8.93000% is in excess of allowable threshold of APOR 4.23% + 1.5%, or 5.73000%.  Compliant Higher Priced Mortgage Loan.

verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643224

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

22.51% DTI on this Full documentation loan < 50% guideline max - 27.49% below program guideline maximum 36.78 months reserves > 3 months guideline minimum - borrowers have verified reserves of $57,062.70

Reviewer Comment (2017-04-04): Client elects to waive.

04/04/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643224

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Loan file does not contain evidence of borrower's consent to receive electronic disclosures.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201643225

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Final closing disclosure was signed on [MM/DD/YYYY], closing disclosure states closing date [MM/DD/YYYY]

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

B

B

201643225

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

B

B

201643225

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

B

B

201643228

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-04-17): CDA was ordered and received supporting the Original Appraisal Value. Reviewer Comment (2017-04-17): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201643228

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643228

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $87.00 exceeds tolerance of $75.00 plus 10% or $82.50.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-04-05): Cured at closing.

04/05/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201643228

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $450.00 exceeds tolerance of $435.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-04-05): Cured at closing.

04/05/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201643228

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved exception to allow 90% LTV. Compensating factors of 35% DTI, excess residual income and 0x30 in last 24 months

Residual income $5700 above the required $4500 34.50% DTI on this full documentation loan < 50.00% guideline max - 15.50% below program guideline maximum

Reviewer Comment (2017-04-12): Client elects to waive.

04/12/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643228

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.25580% or Final Disclosure APR of 7.25600% is in excess of allowable threshold of APOR 3.64% + 2.5%, or 6.14000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643229

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.24290% or Final Disclosure APR of 6.24300% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643229

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Updated closing disclosure provided on [MM/DD/YYYY] showed correct closing date of [MM/DD/YYYY]

Reviewer Comment (2017-04-05): corrected on CD dated 3/22/17 which is signed by the borrower

04/05/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201643229

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Final CD was not provided.  Credit reflects on post-close.

Reviewer Comment (2017-04-05): Lender provided $66.74 lender credit on CD dated 3/22/17, which is signed by the borrower.

04/05/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643229

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $66.74 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7520)

Credit reflects on post-close.

Reviewer Comment (2017-04-05): Lender provided $66.74 lender credit on CD dated 3/22/17, which is signed by the borrower.

04/05/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643229

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on[MM/DD/YYYY], prior to three (3) business days from transaction date of[MM/DD/YYYY].

Updated Closing provided on [MM/DD/YYYY] showed disbursement date as [MM/DD/YYYY].

Reviewer Comment (2017-04-05): CD dated 3/22/17 shows a disbursement date of 3/27/17

04/05/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201643230

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.77570% or Final Disclosure APR of 6.77700% is in excess of allowable threshold of APOR 4.25% + 2.5%, or 6.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201643230

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.77570% or Final Disclosure APR of 6.77700% is in excess of allowable threshold of APOR 4.25% + 2.5%, or 6.75000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

B

B

201643230

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure. Transfer Tax for $808.50, 2nd Inst. Taxes for $3,877.34, Home Warranty for $595, Natural Hazard Disclosure for $99, Real Estate Commission for $18,375, Real Estate Commission for $18,375, Title - Owner's Title Insurance for $898, Utilities through COE for $100 and Utilities through COE for $226.28 were reflected on the Seller's CD, however some, but not all, were not reflected on the Borrower's Final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201643231

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Not a safe harbor loan. Exception fired due to lender being incorrect on valuation

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201643231

Compliance

Compliance

State Compliance

California HPML Threshold Test

California Higher-Priced Loan: APR on subject loan of 6.25080% or Final Disclosure APR of 6.25100% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201643231

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Received valid CoC regarding discount point.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

A

B

A

B

A

B

A

B

A

Non QM

Non QM

Yes

C

B

201643231

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $1,237.50 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7200)

Fee is paid by seller but still needs to be accurately disclosed.

Reviewer Comment (2017-04-17): Received valid CoC regarding discount point.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201643231

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643231

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

DTI is over max guideline of 50%, no lender exception provided

Borrower on this full documentation loan has a disposable income of $8484 12 months > required 9 months.

Reviewer Comment (2017-04-18): Client elects to waive.

04/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643231

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.25080% or Final Disclosure APR of 6.25100% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643231

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

DTI is greater than max 50% per guidelines

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643231

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201643231

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI is greater than max 50% per guidelines

Reviewer Comment (2017-04-18): All guideline violations have been addressed by client.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643231

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.25080% or Final Disclosure APR of 6.25100% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201643232

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-04-17): CDA was ordered and received supporting the Original Appraisal Value.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201643232

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.40130% or Final Disclosure APR of 6.40100% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643232

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $13,481.40, while closing CD seller's fees total $13.481.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643232

Credit

Credit

Misc

Credit Exception:

Borrower was charged for a Desk review on the Final CD.  Evidence of Refund to the borrower, PCCD, LOX and proof of delivery are required.

Reviewer Comment (2017-04-18): Seller provided a refund, PCCD, LOX and proof of delivery for the Desk review fee that was charged to the borrower.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643559

Credit

Borrower and Mortgage Eligibility

Borrower Eligibility

Guideline Issue: Number of properties financed exceeds amount allowed by guidelines.

Lender approved exception to allow 7 financed properties.  Guidelines allow a maximum of 5 financed properties with Lender.

739 representative FICO score > 620 guideline minimum - 119 points above guideline minimum 33.73% DTI on this full documentation loan < 43.00% guideline max - 9% below program guideline maximum Borrower on this full documentation loan has a residual income of 11,959.71. Required is $1,300.

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Investment

Purchase

C

B

C

B

C

B

C

B

C

B

Exempt from ATR

N/A

No

C

B

201643559

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees on seller closing disclosure are $13,926.80. Seller paid costs on Final Closing disclosure are $16,343.00.

2

[REDACTED]

[REDACTED]

Investment

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

Yes

C

B

201643559

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Purchase

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

C

B

201643560

Credit

Loan Package Documentation

Application / Processing

Missing Document: HOA Questionnaire not provided

HOA questionnaire has not been provided.

Reviewer Comment (2017-04-17): Not required.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201643560

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-04-17): CDA was ordered and received supporting the Original appraisal value.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201643560

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.49440% or Final Disclosure APR of 6.49400% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

The loan is designated as higher priced.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643560

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (Final/[MM/DD/YYYY])

Homeowners insurance collected in the prepaids is $764.54 which includes a $25.00 service fee.  The monthly homeowners insurance collected is the base policy price of 739.54.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643560

Credit

Credit

Misc

Credit Exception:

Borrower was Charged for a Desk review on the Final CD.  Proof of refund, PCCD, LOX to the borrower and evidence of delivery is required.

Reviewer Comment (2017-04-18): Received copy of check, corrected CD, proof of delivery and LOE to borrower.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643561

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.73880% or Final Disclosure APR of 7.73900% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643561

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-05): Cure of $1.00 was provided on the final CD for Transfer Taxes. No tolerance violation of Title - Insurance Binder fee due to fee being paid by the seller.

04/05/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643561

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643561

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,148.00 exceeds tolerance of $1,147.00.  Insufficent or no cure was provided to the borrower. (8304)

Reviewer Comment (2017-04-05): Cure of $1.00 was provided on the final CD.

04/05/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643561

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender approved the exception.

25.59% DTI on this full documentation loan < 50% guideline max - 24.41% below program guideline maximum Borrower on this Full documentation loan has a disposable income of $7,292.05 and is $4,942.05 higher than the minimum of $2,350.00 required. Borrower receives bonus income not used to qualify the loan.

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643561

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

25.59% DTI on this full documentation loan < 50% guideline max - 24.41% below program guideline maximum Borrower on this Full documentation loan has a disposable income of $7,292.05 and is $4,942.05 higher than the minimum of $2,350.00 required. Borrower receives bonus income not used to qualify the loan.

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643562

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.31320% or Final Disclosure APR of 6.31300% is in excess of allowable threshold of APOR 3.47% + 2.5%, or 5.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643562

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Closing Date that did not match the actual date of consummation. (Final/[MM/DD/YYYY])

Consummation date of [MM/DD/YYYY]. Final closing disclosure reflects a closing date of [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643562

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Received evidence that borrower received disclosure within timing requirements.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201643562

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643562

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Payment Shock exceeds credit guidelines.

Lender approved exception to allow payment shock for first time home buyer to exceed 250%.

Residual Income; Required is $9800; Verified $44,336.57 DTI 33.678%; Maximum 50%

Reviewer Comment (2017-04-10): Client elects to waive.

04/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643562

Credit

Credit

Misc

Credit Exception:

Per guidelines, RSU income can be used with the most recent paystub evidencing receipt of RSU income or a letter from the employer evidencing receipt. Paystub in file do not reflect receipt of RSU, therefore a letter from the employer is required.

Reviewer Comment (2017-04-18): Received guideline clarification that previous years paystubs with proof of receipt is sufficient.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201643562

Credit

Assets

Asset Calculation / Analysis

Cash available for Closing is insufficient to cover Cash From Borrower.

Per RICACO Comments, UW condition was set for the  Balloon Note to paid off  prior to closing subject transaction.  No evidence provided for this payoff so Balloon amount of $190k reduced from liquid assets.

Residual Income; Required is $9800; Verified $44,336.57 DTI 33.678%; Maximum 50%

Reviewer Comment (2017-04-18): Client has elected to waive the requirement that the Balloon Note be paid off prior to closing.  They have moved it to a post closing condition.  Funds for payoff have been added back to available assets and borrower has sufficient cash to close.

04/18/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643562

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - QM

Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Higher Priced QM does not match Due Diligence Loan Designation of ATR Risk.

The loan is being identified as ATR Risk based on the loan not meeting the lender's guidelines related to the documentation of the RSU stock plan.  The stock grants are an integral part of the income being considered with a significant impact on the DTI and corresponding Ability to Repay if access to the funds is deferred for vesting or other constraints.

Reviewer Comment (2017-04-18): AMC considers this loan to meet Appendix Q documentation requirements for the employee stock related income and therefore the loan will be considered as a Qualified Mortgage.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201643562

Compliance

Compliance

Miscellaneous Compliance

Miscellaneous Compliance:  Non-Material Compliance Exception:

The consumer's income included significant employee stock related income; which is not specifically permitted or disallowed within Appendix Q.  The income qualification was based on the stock options that were considered by the lender in a similar manner as bonus income for continuance.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201643563

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.55860% or Final Disclosure APR of 6.57800% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643563

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643563

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $100.00 exceeds tolerance of $50.00 plus 10% or $55.00.  Insufficient or no cure was provided to the borrower. (0)

Reviewer Comment (2017-04-11): Received evidence that seller paid portion is a seller paid fee and not part of tolerance testing.

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201643563

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

15 months reserves > 3 months guideline minimum

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643564

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Lender Approved.

42.77197% DTI on this Full documentation loan < 50% guideline max - 7.22803% below program guideline maximum Borrower on this Full documentation loan has a disposable income of $6739.82 > $2830 minimum exceeds by $3909.82

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643564

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

42.77197% DTI on this Full documentation loan < 50% guideline max - 7.22803% below program guideline maximum Borrower on this Full documentation loan has a disposable income of $6739.82 > $2830 minimum exceeds by $3909.82

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643564

Credit

Loan Package Documentation

Application / Processing

Missing Document: HOA Questionnaire not provided

Reviewer Comment (2017-04-17): Not required.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643564

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.49020% or Final Disclosure APR of 9.49000% is in excess of allowable threshold of APOR 4.25% + 1.5%, or 5.75000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643564

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643564

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,777.40 exceeds tolerance of $2,431.00 plus 10% or $2,674.10.  Insufficient or no cure was provided to the borrower. (0)

A $103.30 tolerance violation.

Reviewer Comment (2017-04-06): Final CD reflects $146.41 Lender Credit for tolerance cure.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201643566

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

79 months reserves > 9 months guideline minimum

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643566

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.04540% or Final Disclosure APR of 7.04500% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643566

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflects  $17,150.50.   Borrower's CD reflects $98,807.58.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643567

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643567

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

15 months reserves > 3 months guideline minimum

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643567

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.46710% or Final Disclosure APR of 8.47000% is in excess of allowable threshold of APOR 3.60% + 1.5%, or 5.10000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643568

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Secondary valuation has not been provided.

25 months reserves > 3 months guideline minimum

Reviewer Comment (2017-04-06): Client elects to waive.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201643568

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.17830% or Final Disclosure APR of 6.19700% is in excess of allowable threshold of APOR 3.60% + 2.5%, or 6.10000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201643568

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Evidence of earlier borrower receipt has not been provided.

Reviewer Comment (2017-04-17): Seller provided evidence that the LE was provided within the time required. Reviewer Comment (2017-04-11): Received Acknowledgement Of Receipt of LE for 2/23 LE (signed 3/14 and 3/15) but this does not provide proof of receipt of the 3/14 LE.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201643568

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller's CD reflectsl $59,670.47.  Borrower's CD reflects $59,570.47.    Subsequent disclosure corrects data, however no evidence of letter of explanation found in file.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643568

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $196.00 exceeds tolerance of $136.00 plus 10% or $149.60.  Sufficient or excess cure was provided to the borrower at Closing. (0)

Reviewer Comment (2017-04-06): Cured at closing.

04/06/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201643568

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan allows for Assumption. (Final/[MM/DD/YYYY])

CD reflects not assumable.  Note reflects assumable after initial fixed rate period.  Data is still not accurate on Post Close CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201643569

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.45490% or Final Disclosure APR of 6.45500% is in excess of allowable threshold of APOR 3.46% + 2.5%, or 5.96000%.  Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643569

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

CD reflects $77.38, calculates to be $2512.46.  Cure for $9.70 increase in recording fees and $2502.76 decrease in Lender Credit was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643569

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $189.00 exceeds tolerance of $163.00 plus 10% or $179.30.  Insufficient or no cure was provided to the borrower. (0)

$9.70 tolerance violation.  Although $18 of this fee was seller paid it is still included in tolerance testing.

Reviewer Comment (2017-04-17): Received evidence that seller paid portion is for trust recording and not buyer paid fee.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201643569

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $112.38 exceeds tolerance of $60.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-04-06): Final CD reflects $77.38 Lender Credit for tolerance cure.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201643569

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Employment Fee.  Fee Amount of $60.00 exceeds tolerance of $35.00.  Insufficent or no cure was provided to the borrower. (7571)

A lender credit in the amount of 77.38 was issued at closing which is sufficient to cure the under disclosure.

Reviewer Comment (2017-04-06): Final CD reflects $77.38 Lender Credit for tolerance cure.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201643569

Compliance

Compliance

Federal Compliance

TRID non-compliant: Fees were not reflected in the correct section of the disclosure.

$2,502.64 Lender credit for HOA premium reflected in Summaries of Transactions should be reflected in section F, line 1 under paid by others.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643569

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-3,819.24  is less than amount of binding Lender Credit previously disclosed in the amount of $-6,322.00. (9300)

First Loan Estimate reflects $6322 Lender Credit (loan was locked) and Final CD reflects $3819.24 Lender paid fees.  Valid Changed Circumstance was not found in file to justify this decreased lender credit.   Note:  $2502.64 Lender Credit for HOI fees is reflected in Summaries of Transactions which brings total of Lender paid fees to $6321.88.

Reviewer Comment (2017-04-17): Received corrected CD with fees moved to correct section.  Credit sufficient.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201643783

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $92.00 exceeds tolerance of $85.00.  Sufficient or excess cure was provided to the borrower at Closing. (7580)

Reviewer Comment (2017-04-06): Cure of $752 provided on final CD.

04/06/2017

1

[REDACTED]

[REDACTED]

Primary

Refinance - Limited Cash-out GSE

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

B

B

201643783

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

TILA-RESPA Integrated Disclosure - Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction.

Discrepancy noted on page 1 of LE dated [MM/DD/YYYY].

Reviewer Comment (2017-04-06): Data was corrected on subsequent disclosures.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Refinance - Limited Cash-out GSE

Good Faith Redisclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201643784

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.94180% or Final Disclosure APR of 7.94100% is in excess of allowable threshold of APOR 4.14% + 1.5%, or 5.64000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643784

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Final closing disclosure reflects a conveyance tax of $10.00 in section E that was paid by the borrower.  This fee was not disclosed on the Loan Estimate.  A cure of $10.00 is on the final closing disclosure.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643784

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643784

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Missing secondary valuation.

23 months reserves > 6 months guideline minimum

Reviewer Comment (2017-04-07): Client elects to waive.

04/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643784

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Borrowers used the vendor on SSPL, however, the Lender Title Insurance fee was listed on section C instead of section B of Closing Disclosure.

Reviewer Comment (2017-04-17): Seller provided a PCCD, and LOX to the borrower moving the fee's to section B on the CD.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201643785

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.13590% or Final Disclosure APR of 7.14000% is in excess of allowable threshold of APOR 4.19% + 1.5%, or 5.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643785

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-06): Cure of 38.29 was provided on the final CD to cure credit report fee.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643785

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Total seller paid fees on Seller's Closing Disclosure of $5,935 are greater than the disclosed seller paid fees on Borrower's Final Closing Disclosure of $875.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643785

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $67.29 exceeds tolerance of $32.00.  Insufficent or no cure was provided to the borrower. (7520)

Reviewer Comment (2017-04-06): Cure of $38.29 was provided on the final CD.

04/06/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201643785

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

718 representative FICO score > 680 guideline minimum - 38 points above guideline minimum

Reviewer Comment (2017-04-07): Client elects to waive.

04/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643787

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.10030% or Final Disclosure APR of 7.10000% is in excess of allowable threshold of APOR 3.48% + 1.5%, or 4.98000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643787

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643787

Credit

Loan Package Documentation

Closing / Title

Title: Evidence of title is missing

Reviewer Comment (2017-04-11): Received copy of final title.

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643788

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

689 representative FICO score > 620 guideline minimum - 69 points above guideline minimum

Reviewer Comment (2017-04-07): Client elects to waive.

04/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201643788

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Deposit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the Deposit. (Final/[MM/DD/YYYY])

Borrower did not make a deposit.  Down payment is gift of equity.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643788

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Cure for Lender Credit  of  $94.00 was not provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643788

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-04-11): Received evidence that borrower received disclosure within timing requirements.

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643788

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-1,350.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,444.00. (9300)

Final Loan Estimate reflects a lender credit of $1444. Final Closing Disclosure reflects lender credit of $1,350.00. No cure was provided.

Reviewer Comment (2017-04-17): Received corrected CD with fees moved to correct section.  Credit sufficient.

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201643788

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller closing disclosure reflects $1,980.92. Final Closing disclosure reflects $127,147.10 which includes the payoff of the lien on the subject property of $120,507.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201643788

Credit

Credit

Misc

Credit Exception:

Final closing disclosure shows gift in borrower's name.  Should reflect gift of equity from seller.

Reviewer Comment (2017-04-17): Gift verbiage corrected to reflect seller.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201643788

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.89720% or Final Disclosure APR of 6.89700% is in excess of allowable threshold of APOR 3.64% + 1.5%, or 5.14000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201643788

Credit

Credit

Misc

Credit Exception:

Lender approved as a Tier 2. Housing history payment is required, but not provided. Final 1003 shows borrower is renting and shows rental payment as $1.00.

Reviewer Comment (2017-04-11): Received letter from relative stating no rent required.

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201644995

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Fee collected but no report provided.

Reviewer Comment (2017-04-17): Seller provided evidence of the refund to the borrower.  CDA was ordered and received supporting the original appraisal value.

04/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201644995

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201644996

Credit

Loan Package Documentation

Application / Processing

Missing Document: AUS not provided

Reviewer Comment (2017-04-11): Received AUS.

04/11/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

A

C

A

C

A

C

A

C

A

Exempt from ATR

N/A

No

C

B

201644996

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception for DTI.

55.41% LTV < 85.00 guideline max -  $109,500 more equity than required by program guidelines

Reviewer Comment (2017-04-07): Client elects to waive.

04/07/2017

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Exempt from ATR

N/A

No

C

B

201644996

Compliance

Compliance

Federal Compliance

Investment Property submitted as Non-QM / Exempt from ATR

Ability to Repay (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Ability to Repay requirements.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Exempt from ATR

N/A

No

C

B

201644996

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-04-11): Received evidence that borrower received disclosure within timing requirements.

04/11/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Exempt from ATR

N/A

No

C

B

201644996

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on[MM/DD/YYYY] not received by borrower at least four (4) business days prior to closing. (Interim/[MM/DD/YYYY])

Reviewer Comment (2017-04-11): Received evidence that borrower received disclosure within timing requirements.

04/11/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Exempt from ATR

N/A

No

C

B

201644996

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-04-06): Cure of $150 provided on final CD.

04/06/2017

1

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

A

A

A

A

A

A

A

A

A

A

Exempt from ATR

N/A

Yes

C

B

201644997

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201644997

Credit

Credit

Misc

Credit Exception:

Lender approved exception. Omission of $1,678.22 auto loan from the DTI-paid by business-auto loan opened in April 2016-Less than 12 months payments verified-12 months April 2017.

Residual income minimum guideline requirements $3,700. Actual amount $6,041.78, exceeds by $2,341.78. Cash reserves of 76 months > 3 months guideline minimum.

Reviewer Comment (2017-04-07): Client elects to waive.

04/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201644999

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.56940% or Final Disclosure APR of 8.56900% is in excess of allowable threshold of APOR 3.64% + 1.5%, or 5.14000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201644999

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-07): Cure was provided on final CD

04/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201644999

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller closing disclosure reflects seller paid fees of $10,332.00.  Final Closing Disclosure reflects seller paid fees of $10,293.73.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201644999

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficent or no cure was provided to the borrower. (7505)

Appraisal Desk review was not disclosed on the Loan Estimate.

Reviewer Comment (2017-04-07): Cure on final closing disclosure of $150.00

04/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201644999

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,482.00 exceeds tolerance of $572.00.  Insufficent or no cure was provided to the borrower. (8304)

In the State of FL it is customary for the borrower to pay Transfer tax on the mortgage and seller to pay the transfer tax on the Deed. Final closing disclosure reflects $572.00 as borrower paid and $910.00 as seller paid. Total transfer tax is $1,482.00. No cure is required.

Reviewer Comment (2017-04-07): No cure required

04/07/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201644999

Credit

Insurance

Insurance Documentation

Missing Document: Hazard Insurance Policy not provided

Subject property is a condominium. File contains HO-6 coverage only.  Missing evidence of blanket coverage for building.

Reviewer Comment (2017-04-11): Received copy of Blanket Policy.

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201644999

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on[MM/DD/YYYY] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201645000

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Total cash-out discrepancy.

An exception was provided by the lender

Residual income of $74,657.66 is above the minimum required amount of $10,000 for an excess of $64,657.66. Reserves of 10 months are in excess of program minimum 3 months required. DTI 37.523% is below program maximum of 43% with using Note+ 2%. LTV of 70.971% is below program maximum of 85%. Guidelines require a 24 month payment history and UW has verified 45 month's payment history with [REDACTED].

Reviewer Comment (2017-04-10): Client elects to waive.

04/10/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201645000

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

An exception was granted by the lender

Residual income of $74,657.66 is above the minimum required amount of $10,000 for an excess of $64,657.66. Reserves of 10 months are in excess of program minimum 3 months required. DTI 37.523% is below program maximum of 43% with using Note+ 2%. LTV of 70.971% is below program maximum of 85%. Guidelines require a 24 month payment history and UW has verified 45 month's payment history with [REDACTED].

Reviewer Comment (2017-04-10): Client elects to waive.

04/10/2017

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201645000

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201645000

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-15,863.00. (9300)

Reviewer Comment (2017-04-17): Received corrected CD with fees moved to correct section.  Credit sufficient.

04/17/2017

1

[REDACTED]

[REDACTED]

Second Home

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

Yes

C

B

201646556

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.90260% or Final Disclosure APR of 6.90300% is in excess of allowable threshold of APOR 3.46% + 1.5%, or 4.96000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201646556

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller Closing Disclosure Seller Paid Fees Total $14,857.50. Closing Disclosure Calculated Closing Costs Subtotals Paid By Seller At Closing 13,499.50.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201646556

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Lender exception in file for FICO score. Borrower has a 674, 680 is required for a Tier 2 non-warrantable condo.  Compensating factors are LTV, residual income.

Guidelines require Residual income of $800. Actual Residual Income is $4,564.14. Maximum LTV per guidelines si 85%.  Actual LTV is 80%.

Reviewer Comment (2017-04-10): Client elects to waive.

04/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

No

C

B

201646556

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-04-18): CDA was ordered and received supporting the original appraisal value.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201646557

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-04-18): CDA Was ordered and received supporting the original appraisal value.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201646557

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.27410% or Final Disclosure APR of 7.27400% is in excess of allowable threshold of APOR 4.14% + 1.5%, or 5.64000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201646557

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201646558

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-04-18): CDA was ordered and received supporting the original appraisal value.

04/18/2017

1

[REDACTED]

[REDACTED]

Second Home

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201646558

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201646558

Credit

Credit

Misc

Credit Exception:

Lender approved exception for Non-Warrantable condo Risk Level 3. Minimum FICO of 700 was not met.

Maximum LTV of 75%. Actual LTV of 69.93%. 57 months reserves >6 months guideline minimum - borrowers have verified reserves of $122,291.64. Residual income  required of $1350.  Acutal residual income is $3965.19.

Reviewer Comment (2017-04-10): Client elects to waive.

04/10/2017

2

[REDACTED]

[REDACTED]

Second Home

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201646559

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender approved exception in file allow DTI to exceed. guideline maximum of 50%. Lender DTI is 53.923% versus review DTI of 50.819%. Lender qualified using the net pension income. Review DTI is based on gross benefit.

Borrower LTV is 10% below max for program Borrower has over 50 months reserves

Reviewer Comment (2017-04-10): Client elects to waive.

04/10/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

No

C

B

201646559

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-04-18): CDA was ordered and received supporting the original appraisal value.

04/18/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201646559

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.10880% or Final Disclosure APR of 7.17200% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2017-04-10): All guideline violations have been addressed by client.

04/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201646559

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Ability to Repay)

Federal Higher-Priced Mortgage Loan (Dodd-Frank 2014): Non-compliant - Ability to Repay requirements not satisfied.

Reviewer Comment (2017-04-10): All guideline violations have been addressed by client.

04/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201646559

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2017-04-10): All guideline violations have been addressed by client.

04/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

Lender to provide updated ATR/QM status

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201646559

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Reviewer Comment (2017-04-10): All guideline violations have been addressed by client.

04/10/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201646559

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on[MM/DD/YYYY] disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan. (Final/[MM/DD/YYYY])

TIP per final closing disclosure is 136.515. Calculated TIP is 134.281. Index value used by the lender is 1.70261 which is not on the table provided.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201646559

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

2

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201646559

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-04-12): Seller provided evidence of delivery within 3 days of closing.

04/12/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201646559

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.10880% or Final Disclosure APR of 7.17200% is in excess of allowable threshold of APOR 3.47% + 1.5%, or 4.97000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

Non QM

Non QM

No

C

B

201646560

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.85830% or Final Disclosure APR of 7.85800% is in excess of allowable threshold of APOR 4.20% + 1.5%, or 5.70000%.  Compliant Higher Priced Mortgage Loan.

All fees have been verified as entered from the final CD.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

B

B

201646560

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $9,556.00, while closing CD seller's fees total $129,346.00.  The combined CD includes the sellers mortgage payoff of $119,790.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

B

B

201646562

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.68900% or Final Disclosure APR of 8.68900% is in excess of allowable threshold of APOR 3.60% + 1.5%, or 5.10000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

C

B

201646562

Compliance

Compliance

State Compliance

North Carolina Rate Spread Threshold Test

North Carolina Rate Spread Home Loan: APR on subject loan of 8.68900% or Final Disclosure APR of 8.68900% is in excess of allowable threshold of APOR 3.60% + 1.5%, or 5.10000%.  Compliant Rate Spread Home Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

C

B

201646562

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Data correct on subsequent CDs (SFIG).

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Higher Priced QM

Higher Priced QM

Yes

C

B

201646562

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2017-04-17): Received evidence that borrower received disclosure within timing requirements.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201646562

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-04-17): CDA was ordered and received supporting the original appraisal value.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Higher Priced QM

Higher Priced QM

No

C

B

201646566

Property

Property - Appraisal

Appraisal Documentation

Missing secondary valuation product required for securitization.

Reviewer Comment (2017-04-17): CDA was ordered and received supporting the Original Appraisal Value.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201646566

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.20240% or Final Disclosure APR of 8.20200% is in excess of allowable threshold of APOR 4.19% + 1.5%, or 5.69000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201646566

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201646566

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Lesser than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are less than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Total seller paid fees on Seller's Closing Disclosure of $120,946.40 are less than the disclosed seller paid fees on Borrower's Final Closing Disclosure of $121,846.60

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

Yes

C

B

201648529

Credit

Loan Package Documentation

Application / Processing

Missing Document: HOA Questionnaire not provided

Reviewer Comment (2017-04-17): Not required.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201648529

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.02240% or Final Disclosure APR of 7.02200% is in excess of allowable threshold of APOR 3.60% + 1.5%, or 5.10000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

No

C

B

201648529

Compliance

Compliance

State Compliance

North Carolina Rate Spread Threshold Test

North Carolina Rate Spread Home Loan: APR on subject loan of 7.02240% or Final Disclosure APR of 7.02200% is in excess of allowable threshold of APOR 3.60% + 1.5%, or 5.10000%.  Compliant Rate Spread Home Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Non QM

Non QM

No

C

B

201648529

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure[MM/DD/YYYY] on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.) (Final/[MM/DD/YYYY])

3638 TRID Final Closing Disclosure Missing Seller Paid Fees Primary Residence First Lien

Reviewer Comment (2017-04-17): Seller provided an LOX and Corrected CD reflecting the seller paid fees

04/17/2017

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

B

C

B

Non QM

Non QM

Yes

C

B

201648529

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/[MM/DD/YYYY])

Reviewer Comment (2017-04-17): Seller provided evidence of timely delivery.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

No

C

B

201648529

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Reviewer Comment (2017-04-11): Cure of $150.00 on final closing disclosure

04/11/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

C

B

201648529

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Final Closing Disclosure signature is not dated.

Reviewer Comment (2017-04-17): Seller provided the Final CD including the borrower signature.

04/17/2017

1

[REDACTED]

[REDACTED]

Primary

Purchase

C

A

C

A

C

A

C

A

C

A

Non QM

Non QM

Yes

C

B

201649005

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Secondary/[MM/DD/YYYY])

There is no indication in loan file that borrower received appraisal dated [MM/DD/YYYY].

2

[REDACTED]

[REDACTED]

Primary

Purchase

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

No

B

B

201649005

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.24120% or Final Disclosure APR of 9.28500% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Higher Priced Mortgage Loan.

2

[REDACTED]

[REDACTED]

Primary

Purchase

A

A

A

A

A

A

A

A

A

A

Higher Priced QM

Higher Priced QM

No

B

B

201649005

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous exception. These fees were paid by seller.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201649005

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

Seller paid fees on the seller CD are $15,093.00. Seller paid Fees on final closing disclosure of $10,886.72. Seller paid fees on post closing disclosure dated [MM/DD/YYYY] of $13,093.00.

2

[REDACTED]

[REDACTED]

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201649006

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on[MM/DD/YYYY] did not disclose the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/[MM/DD/YYYY])

Erroneous reg ID 2933. No tolerance violation for Transfer Tax fee. Tolerance violation comes from split of transfer taxes. Portion in the amount of $1,005.30 was paid by the borrower and $1,505 was paid by the seller.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201649006

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees Greater than Final Closing Disclosure Seller Paid Fees

TILA-RESPA Integrated Disclosure:  Fees disclosed on the Seller's Closing Disclosure are greater than the Seller Paid fees disclosed on the Consumer's Final Closing Disclosure. (Final/[MM/DD/YYYY])

TRID non-compliant. Total seller paid fees on Seller's Closing Disclosure of $13,230.64 are greater than the disclosed seller paid fees on Borrower's Final Closing Disclosure of $13,180.64.

2

[REDACTED]

[REDACTED]

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

Higher Priced QM

Yes

B

B

201649010

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on[MM/DD/YYYY] incorrectly disclosed whether the loan contains a Demand Feature. (Final/[MM/DD/YYYY])

Demand feature was not selected on page 4 of final CD.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

Yes

B

B

201649010

Compliance

Compliance

Federal Compliance

Investment Property Submitted as QM

Qualified Mortgage (Dodd-Frank 2014): Improper Originator Loan Designation. Investment property not subject to Qualified Mortgage requirements.

2

[REDACTED]

[REDACTED]

Investment

Refinance - Cash-out - Other

B

B

B

B

B

B

B

B

B

B

Higher Priced QM

N/A

No

B

B