EX-99.17 18 ex99-17.htm CONSOLIDATED ANALYTICS, INC. (CONSOLIDATED) EXECUTIVE SUMMARY
 

Angel Oak Mortgage Trust I, LLC ABS-15G

Exhibit 99.17

 

 

EXECUTIVE SUMMARY
Third Party Due Diligence Review

 

Overview

 

Consolidated Analytics, Inc (“Consolidated Analytics”), a third-party due diligence provider, performed the review described below on behalf of Angel Oak Mortgage Operating Partnership, LP and Angel Oak Real Estate Investment Trust III (the “Client”). The review included a total of 219 newly originated residential mortgage loans, in connection with the securitization identified as Angel Oak Mortgage Trust 2024-13 (the “Securitization”). The Review was conducted from February 2022 through November 2024 on mortgage loans originated between January 2022 and November 2024.

 

Scope of Review

 

Credit Review

 

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

 

The Credit Review attempted to confirm the following:

 

a.QM or ATR Validation / Review of 8 Key Underwriting Factors
i.Income / Assets
Validate borrower(s) monthly gross income
Validate funds required to close, required reserves
Review file documentation for required level of income and asset verifications
ii.Employment Status
Review file documentation for required level of employment
iii.Monthly Mortgage Payment
Confirm program, qualifying rate, terms
iv.Simultaneous Loans
Validate all concurrent loans are included in the DTI to properly assess the ability to repay
v.Mortgage Related Obligations: PITI, HOA, PMI, etc.
Validate subject loan monthly payment (PITI) and associated obligations
vi.Debts / Obligations
Validate monthly recurring liabilities
vii.DTI and/or Residual Income
Validate debt-to-income ratio (DTI) based upon income and debt documentation provided in the file
Documentation meets Appendix Q requirements for QM Loans
viii.Credit History
Review credit report for credit history and required credit depth including any / all inquiries
Determine representative credit score from credit report

 

b.Validate loan-to-value (LTV) and combined loan-to-value
c.Review borrower’s occupancy

 

 

 

d.Validation through third party resource of the subject properties most recent twelve (12) month sales history
e.Confirm sufficient evidence in loan file, by reviewing the underwriter’s decision to approve the loan based upon the borrows income, debt, and credit history, to support borrower’s willingness and ability to repay the debt
f.Confirm that Final 1003 is sufficiently completed
g.Provide Audit 1008 with accurate data based on file documentation
h.Confirm Loan Approval conditions were met
i.Review condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any red flags that may deem condominium project ineligible
j.General QM for any loans originated under the GQM Rule

 

i.Pricing Thresholds:

 

a.Pricing for First Lien Loans:

 

i.2.25% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and
ii.3.5% for a first-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and
iii.6.5% for a first-lien covered transaction with a loan amount less than the applicable dollar amount threshold.

 

b.Pricing for Subordinate Lien Loans:

 

i.3.5% for a subordinate-lien covered transaction with a loan amount greater than or equal to the applicable dollar amount threshold; and
ii.6.5% for a subordinate-lien covered transaction with a loan amount less than the applicable dollar amount threshold.

 

c.Pricing for Manufactured Homes:

 

i.2.25% for a first-lien covered transaction secured by a manufactured home with a loan amount equal to or greater than the applicable dollar amount threshold; and
ii.6.5% for a covered transaction secured by a manufactured home with a loan amount less than applicable dollar amount threshold.

 

ii.Consider Income and Assets:

 

Consumer’s current or reasonably expected income or assets (other than the value of the dwelling that secures the loan;
The consumer’s debt obligations, alimony, child support; and
The monthly DTI or residual income.

 

iii.Verification of Income and Assets:

 

a.Verification in compliance with one of the “safe harbor” guidelines will meet the QM verification requirement. A creditor is allowed to “mix and match” provisions of the different guidelines rather than only apply one guideline per loan.

 

 

 

The specific guidelines that the CFPB is designating for the safe harbor are: The GQM Rule provides that if the creditor verifies the consumer’s income or assets, debt obligations, alimony, child support, and monthly DTI or residual income by meeting the standards of certain specified third-party underwriting manuals, then a creditor is presumed to have complied with the verification requirement. These specified manuals are:

 

i.Chapters B3-3 through B3-6 of the Fannie Mae Single Family Selling Guide, published June 3, 2020;
ii.Sections 5102 through 5500 of the Freddie Mac Single-Family Seller/Servicer Guide, published June 10, 2020;
iii.Sections II.A.1 and II.A.4-5 of the Federal Housing Administration’s Single Family Housing Policy Handbook, issued October 24, 2019;
iv.Chapter 4 of the U.S. Department of Veterans Affairs’ Lenders Handbook, revised February 22, 2019;
v.Chapter 4 of the U.S. Department of Agriculture’s Field Office Handbook for the Direct Single Family Housing Program, revised March 15, 2019; and
vi.Chapters 9 through 11 of the U.S. Department of Agriculture’s Handbook for the Single Family Guaranteed Loan Program, revised March 19, 2020.

 

Compliance Review

 

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

 

a.Test Loan Estimate(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations

 

b.Test Closing Disclosure(s) for accuracy and completeness as well as timing requirements as required by TRID Regulations

 

c.Tolerance Testing
i.Compare Loan Estimate and Closing Disclosures
ii.Identify Tolerance Violations and applicable cost to cure

 

d.Comprehensive review of Closing Disclosure to determine transaction accuracy

 

e.Recalculation of APR and Finance Charge

 

f.Testing of:
i.Federal High Cost Mortgage provisions
ii.Federal Higher Priced Mortgage Loans provisions
iii.Local and/or State Anti-predatory and High Cost provisions
iv.HOEPA Points and Fees

 

g.Determine whether specified federal disclosures were provided timely based upon comparison of the application date to the dates on such disclosures
i.Service Provider List
ii.Home Ownership Counselling Disclosure
iii.ARM Disclosure

 

h.Compliance with QM as it relates to:
i.APR Test
ii.Points & Fees Test
iii.Prepayment Penalty Test
iv.Product Eligibility Testing

 

i.Notice of Right to Cancel (Rescission) Review
i.Confirm transaction date, expiration date, and disbursement date

 

 

 

ii.Confirm document is properly executed by all required parties to the transaction
iii.Confirm the correct Right of Rescission document was executed for the transaction type

 

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

 

k.Check the Loan participants against the exclusionary list provided by Clients or by the purchaser of the Loan(s)

 

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

 

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

 

Valuation Review

 

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

 

a.Review original appraisal, determination that property is in “average” condition or better, or property requires cosmetic improvements (as defined by the appraiser) that do not affect habitability. Should an area of concern be identified with the condition of the property, Consolidated Analytics will alert Clients.
b.Review appraisal, determination that property is completely constructed and appraisal is on an “as is basis,” or property is identified as not completely constructed by originating appraiser.
c.Review and determine if the appraisal report was performed on appropriate GSE forms and if the appraiser indicated in the body of the subject appraisal that the appraisal conforms to USPAP standards.
d.Review and determine the relevance of the comparable properties and ensure that a rational and reliable value was provided and supported as of the effective date of the Origination Appraisal.
e.Review adjustments (line item, net and gross adjustments) to ensure they are reasonable.
f.Ensure that the appraisal conforms to the guidelines provided from the Clients.
g.Review appraisal to ensure all required documents were included.
h.Review location map provided within the appraisal for external obsolescence.
i.Ensure highest and best use and zoning complies with guidelines.
j.Confirm there are no marketability issues that affect the subject property.
k.Ensure subject property does not suffer any functional obsolescence.
l.Where applicable, determine if the file did not contain the appraisal or other valuation method and a review could not be performed.
m.Additional valuation products were not required when the CU score provided was 2.5 or below or the appraisal LCA risk score was eligible for Collateral Rep and Warranty relief. In the event the CU score was greater than 2.5 or the LCA score was not eligible for R&W relief, an additional valuation product was obtained to confirm value was supported within 10% tolerance. In some instances, based on guidance from the seller, CDA’s were ordered on loans that had an acceptable CU score or R&W eligibility.

 

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

 

 

 

For loans reviewed in a post-close valuation review scenario (219 loans in total):

 

One hundred and fifty-four (154) loans had CU scores of 2.5 or less or were eligible for Collateral Rep and Warranty relief.

 

Twenty-four (24) loans had an AVM, eight (8) loans had Secondary Appraisals, and fifty-two (52) loans had a Desktop Review. Consolidated Analytics has independent access to the Desktop Reviews ordered by the Aggregator.

 

If a loan with an AVM or Desktop Review fell outside of a -10% tolerance, was inconclusive, or a PIW was present, then an additional valuation product was completed. There were zero (0) instances of this.

 

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

 

TAPE INTEGRITY REVIEW RESULTS SUMMARY

 

Of the 219 mortgage loans reviewed, one hundred (119) unique mortgage loans (54.34% by loan count) had a total of two-hundred and thirty (230) tape discrepancies across fifteen (15) data fields. A blank or zero value on the data tape when an actual value was captured by Consolidated Analytics was not treated as a data variance.

 

Fields Reviewed Discrepancy Count Percentage
Qualifying All Borrower Residual Income 68 29.57%
QM Qualifying Total Debt Income Ratio 47 20.43%
Qualifying Total Reserves Number of Months 40 17.39%
Months Reserves 22 9.57%
DSCR 17 7.39%
Gross Rent 12 5.22%
Property Type 7 3.04%
Qualifying FICO 5 2.17%
Cash Disbursement Date 3 1.30%
Originator DTI 2 0.87%
Application Date 2 0.87%
Occupancy 2 0.87%
LTV 1 0.43%
Original LTV 1 0.43%
Original CLTV 1 0.43%
Grand Total 230 100.00%

 

 

 

Summary of Results

 

OVERALL RESULTS SUMMARY

 

Final Loan Grades

 

Overall Loan Results:  
Event Grade Loan Count Original Principal Balance Percent of Sample
Event Grade A 192 $88,887,580.00 87.67%
Event Grade B 27 $16,148,788.00 12.33%
Event Grade C 0 $0.00 0.00%
Event Grade D 0 $0.00 0.00%
Total Sample 219 $105,036,368.00 100.00%

 

Credit Results:
Event Grade Loan Count Percent of Sample
Event Grade A 202 92.24%
Event Grade B 17 7.76%
Event Grade C 0 0.00%
Event Grade D 0 0.00%
Total Sample 219 100.00%

 

Compliance Results:
Event Grade Loan Count Percent of Sample
Event Grade A 213 97.26%
Event Grade B 6 2.74%
Event Grade C 0 0.00%
Event Grade D 0 0.00%
Total Sample 219 100.00%

 

 

 

Valuation Results:
Event Grade Loan Count Percent of Sample
Event Grade A 213 97.26%
Event Grade B 6 2.74%
Event Grade C 0 0%
Event Grade D 0 0%
Total Sample 219 100.00%


 

Exception Category Summary

 

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

 

Exception Type Exception Level Grade Exception Category Total
Credit   No Credit Findings 145
Deed Missing or Defective 10
Credit Report Missing or Defective 4
Credit Report Aged 4
Closing Protection Letter Missing or Defective 3
ATR: Current Employment Not Verified 3
Hazard insurance dwelling coverage is not sufficient 2
Purchase Contract is Expired 2
Income and Employment Do Not Meet Guidelines 2
Audited DTI Exceeds Guideline DTI 2
The Initial 1003 is Missing 2
Asset Documentation Missing or Defective 2
Title Insurance Missing or Defective 2
Borrower 1 Credit Report is Missing 1
Occupancy Not Allowed 1
Mortgage Payment History Missing or Defective 1

 

 

 

    Borrower 1 Gap Credit Report is Missing 1
Satisfactory Chain of Title not Provided 1
Borrower 1 Paystubs Missing 1
Missing Letter of Explanation (Assets) 1
Borrower 1 YTD Profit & Loss Missing 1
No Findings 1
Cash Out Does Not Meet Guideline Requirements 1
Purchase is not considered to be an Arm’s Length Transaction 1
Asset Qualification Does Not Meet Guideline Requirements 1
Borrower 1 Credit Report is Expired 1
Audited FICO is less than Guideline FICO 1
Missing letter of explanation 1
Audited Reserves are less than Guideline Required Reserves (Dollar Amount) 1
Missing verification of taxes, insurance, and/or HOA fees for non-subject property 1
Title Insurance Coverage - Inadequate Coverage 1
Asset 3 Does Not Meet Guideline Requirements 1
Background Check Missing or Defective 1
Note Missing or Defective 1
Approval/Underwriting Summary Partially Provided 1
Borrower 1 CPA Letter Missing 1
Borrower 1 3rd Party VOE Prior to Close Missing 1
Rent Loss Insurance Missing 1
Borrower 1 Business Bank Statements Less Than 12 Months Provided 1
The Final 1003 is Incomplete 1
Insufficient Assets for Reserves 1
Title Coverage is Less than Subject Lien 1
Insufficient Assets to Close 1
Minimum Credit Score Requirement Not Met 1
Verification of Borrower Liabilities Missing or Incomplete 1
Entity Documentation - Missing or Defective 1
Guideline Seasoning not Met 1
Total Credit Grade (A) Exceptions: 217
B Audited Reserves are less than Guideline Required Reserves (Dollar Amount) 4
Delinquent Credit History Does Not Meet Guideline Requirements 3
Overdraft/NSF Count Exceeds Tolerance 3
Cash Out Does Not Meet Guideline Requirements 1
Income documentation does not meet guidelines 1

 

 

 

    Housing History Does Not Meet Guideline Requirements 1
Note Missing or Defective 1
Borrower 1 Gap Credit Report is Expired (Greater than 10 Days from Closing/Settlement Date) 1
Payment shock exceeds guideline 1
Entity Documentation - Missing or Defective 1
Unacceptable Mortgage History 1
First Time Homebuyer 1
Guideline Seasoning not Met 1
Total Credit Grade (B) Exceptions: 20
Compliance A No Compliance Findings 88
Missing Credit Score Disclosure (FACTA) 5
Charges That Cannot Increase Test 3
Initial Closing Disclosure Delivery Date Test 3
Initial Loan Estimate Delivery Date Test (from application) 2
Charges That In Total Cannot Increase More Than 10% Test 1
TILA Right of Rescission Test 1
Second Home Rider is Missing 1
Initial Loan Estimate Delivery Date Test (prior to consummation) 1
Evidence of Appraisal Delivery to Borrower not Provided or Late (12 CFR 1002.14(a)(1)) 1
Incorrect rescission model used - RTC form model H-8 used for Same Lender or Lender Affiliate Refinance 1
Total Compliance Grade (A) Exceptions: 107
B Charges That In Total Cannot Increase More Than 10% Test 3
Charges That Cannot Increase Test 2
High-Cost Mortgage Timing of Disclosure Test 1
High-Cost Mortgage Late Fee Test 1
Higher-Priced Mortgage Loan 1
TX SB 1581 High-Cost Home Loan Credit Transaction Points and Fees Threshold Test 1
High-Cost Mortgage Pre-Loan Counseling Date Test 1
High-Cost Mortgage Points and Fees Threshold Test 1
Total Compliance Grade (B) Exceptions: 11
Property A No Property Findings 107
Hazard Insurance Missing or Defective 5
Appraisal Review - Missing 3
Subject Property Lease - Missing or Defective 2
FEMA Declared Disaster Dated Prior to the Note Date, After Appraisal Date 1

 

 

 

    Property Issue(s) are Present 1
Market Rent - Missing or Defective 1
Ineligible Property – Square Footage 1
Total Property Grade (A) Exceptions: 121
B Ineligible Project – Other Charter Violation 2
Property/Appraisal General 1
Property has been listed for sale in the past 6 months 1
HOA Does Not Meet Guidelines 1
Ineligible Property 1
Total Property Grade (B) Exceptions: 6

 

Event Grade Definitions

 

Final Loan Grade
A Loan meets Credit, Compliance, and Valuation Guidelines
B The loan substantially meets published Clients/Seller guidelines and/or eligibility in the validation of income, assets, or credit, is in material compliance with all applicable laws and regulations, and the value and valuation methodology is supported and substantially meets published guidelines.
C The loan does not meet the published guidelines and/or violates one material law or regulation, and/or the value and valuation methodology is not supported or did not meet published guidelines.
D Loan is missing documentation to perform a sufficient review.

 

Credit Event Grades
A The loan meets the published guidelines without any exceptions. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable.
B The loan substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding published guidelines. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable.
C The loan does not substantially meet the published guidelines. There are not sufficient compensating factors that justify exceeding the published guidelines. The employment, income, assets or occupancy are not supported and justifiable. The borrower’s willingness and ability to repay the loan were not documented or are unreasonable.
D There was not sufficient documentation to perform a review or the credit file was not furnished.

 

 

 

Compliance Event Grades
A The loan is in compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties.
B The loan is in material compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. Clients review required.
C The loan violates one material law or regulation. The material disclosures are absent or the legal documents do not accurately reflect the agreed upon loan terms or all required applicants did not execute the documents.
D There was not sufficient documentation to perform a review or the required legal documents were not furnished.

 

Valuation Event Grades
A The value is supported within 10% of the original appraisal by the AVM or there are other supporting documents in the originators loan file package (CDA, Field Review or Second Appraisal). The appraisal was performed on an “as-is” basis and the property is complete and habitable at origination. The appraiser was appropriately licensed and used GSE approved forms.
B The value is not supported within 10% of the original appraisal by the AVM and there are no other valuation support documents in the loan file provided by the Seller. The valuation methodology substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding guidelines. The appraisal was performed on an “as-is” basis and the property is complete and habitable. The appraiser was appropriately licensed and used GSE approved forms.
C The value is not supported within 10% of the original appraisal. The valuation methodology did not meet the published guidelines and there were not sufficient compensating factors for exceeding published guidelines. The property is in below “average” condition or the property is not complete or requires significant repairs. The appraisal was not performed on an “as is” basis. The appraiser was not appropriately licensed or did not use GSE approved forms.
D The file was missing the appraisal or there was not sufficient valuation documentation to perform a review.