EX-99.1 2 exh_99-1.htm DISCLOSURES REQUIRED BY RULE 15GA-2 FOR AMC DILIGENCE, LLC

Exhibit 99.1

 

 

 

 

EXECUTIVE SUMMARY

 

DESCRIPTION OF SERVICES

(1) Type of assets that were reviewed.

AMC Diligence, LLC (“AMCD”) or its subsidiary, through acquisition on December 18, 2015, JCIII & Associates, LLC (“JCIII”; formerly known as JCIII & Associates, Inc.; and together with AMC Diligence, LLC referred to collectively as “AMC”) performed due diligence services as described below utilizing various scopes of review. All of these mortgage loans, which were originated by multiple parties, were purchased by an affiliate of Bayview Fund Management LLC (“Client”) in multiple bulk transactions and were reviewed by AMC on behalf of such party. The mortgage loans were reviewed via files imaged and provided by the Client or its designee for review.

 

(2) Sample size of the assets reviewed.

The diligence review (the “Review”) was conducted on a portion of the securitization mortgage loan population reviewed by AMC. The total population covered during the Review varied by mortgage loan scope. The Client may have utilized multiple third party review (“TPR”) firms for the securitization and AMC may or may not have reviewed all of the mortgage loans in the securitization loan population for a specific scope of review.

 

The mortgage loan review sample was broken down into the following review scopes (the “AMC Population”):

§“Compliance Review”:                                      729 mortgage loans
§“Data Integrity Review”:                                  729 mortgage loans
§“Securitization Payment History Review”:      774 mortgage loans

 

Throughout the securitization process, the Client may have removed or added various mortgage loans from the securitization population for reasons that are unknown to AMC. AMC’s disclosures herein reflect findings on the securitization population (as known by AMC) as of the date hereof.

 

(3) Determination of the sample size and computation.

The AMC Population, to our knowledge, is a subset of all mortgage loans in the securitization population. AMC does not know what percentage of total mortgage loans in the securitization population were reviewed by a third party due diligence provider and therefore we cannot comment as to the sufficiency of such sample as a percentage of the overall securitization population.

 

(4) Quality or integrity of information or data about the assets: review and methodology.

AMC compared certain data fields on the securitization tape provided by Client to the data found in the actual file as captured by AMC or in certain instances to other verification sources provided by the Client. The fields included in the data integrity review are detailed below (please note items with a * represent the latter of the information from the Note or modification, if relevant, on the mortgage loan in question).

 

AMORTIZATION TYPE FIRST PAYMENT DATE MOD FLAG PERIODIC FLOOR*
APPRAISED VALUE FIRST RATE ADJ DATE* MOD LOAN AMOUNT PROPERTY TYPE
ARM INDEX* LIEN POSITION NOTE DATE PROPERTY ADDRESS
BALLOON FLAG* MARGIN* ORIG FICO PROPERTY CITY
BORROWER LAST NAME MAX LIFE RATE* ORIG LOAN AMOUNT PROPERTY STATE
CONTRACT SALES PRICE MIN LIFE RATE* ORIG RATE PROPERTY ZIP
CURRENT MATURITY DATE* MOD DATE ORIGINAL P&I PURPOSE
FIRST PAYMENT ADJ DATE* MOD FIRST PAYMENT DATE PERIODIC CAP* RATE CHANGE FREQ*

 

(5) Origination of the assets and conformity to stated underwriting or credit extension guidelines, standards, criteria or other requirements: review and methodology.

Not applicable.

 

(6) Value of collateral securing the assets: review and methodology.

Not applicable.

 

(7) Compliance of the originator of the assets with federal, state and local laws and regulations: review and methodology.

 

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Please be advised that AMC did not make a determination as to whether the mortgage loans complied with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated below. There can be no assurance that the Review uncovered all relevant factors relating to the origination of the mortgage loans, their compliance with applicable law and regulations and the original appraisals relating to the mortgaged properties or uncovered all relevant factors that could affect the future performance of the mortgage loans. Furthermore, the findings reached by AMC are dependent upon its receiving complete and accurate data regarding the mortgage loans from mortgage loan originators and other third parties upon which AMC is relying in reaching such findings.

 

Please be further advised that AMC does not employ personnel who are licensed to practice law in the various jurisdictions, and the findings set forth in the reports prepared by AMC do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to AMC. Information contained in any AMC report related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the report based on certain factors, including the facts and circumstances of an individual mortgage loan. All final decisions as to whether to purchase or enter into a transaction related to any individual mortgage loan or the mortgage loans in the aggregate, any investment strategy and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such mortgage loan or mortgage loans, shall be made solely by the Client, or other agreed upon party, that has engaged AMC to prepare its reports pursuant to its instructions and guidelines. The Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by AMC are designed to identify potential risk and the Client, or other agreed upon party, assumes sole responsibility for determining the suitability of the information for its particular use. AMC does not make any representation or warranty as to the value of any mortgage loan or mortgage loans collateral that has been reviewed by AMC.

 

AMC reviewed each mortgage loan to determine, as applicable, to the extent possible and subject to the caveats below, whether the mortgage loan complies with:

 

FOR APPLICATION DATES BEFORE JANUARY 10, 2014

(I) Federal Truth in Lending Act (“TILA”), as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below:

a)Rescission (§1026.23):
i)failure to provide the right of rescission notice;
ii)failure to provide the right of rescission notice in a timely manner and to the correct consumer(s);
iii)errors in the right of rescission notice;
iv)failure to provide the correct form of right of rescission notice;
v)failure to provide the three (3) business day rescission period; and
vi)any material disclosure violation on a rescindable loan that gives rise to the right of rescission under TILA, which means the required disclosures of the annual percentage rate, the finance charge, the amount financed, the total of payments, the payment schedule, the HOEPA disclosures;
b)TIL Disclosure (§§1026.17, 18 and 19) as applicable for loans with application dates prior to October 3, 2015:
i)review and comparison of the initial and final TIL disclosures, and any re-disclosed TIL(s);
ii)proper execution by all required parties;
iii)principal and interest calculations, and proper completion of the interest rate and payment summary; and
iv)timing of initial and re-disclosed TIL(s);
c)Tolerances (§§1026.18, 22 and 23):
i)inaccurate Annual Percentage Rate (APR) outside of applicable tolerance by comparing disclosed APR to re-calculated APR; and
ii)inaccurate Finance Charge outside of applicable tolerance by comparing disclosed Finance Charge to re-calculated Finance Charge;
d)High-cost Mortgage (§§1026.31, 32 and 33):
i)points and fees threshold test;
ii)APR threshold test;
iii)prepayment penalty test; and
iv)compliance with the disclosure requirements, limitation on terms and prohibited acts or practices in connection with a high-cost mortgage;
e)Higher-priced Mortgage Loan (§1026.35):
i)APR threshold test; and

 

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ii)compliance with the escrow account and appraisal requirements;

 

(II) Federal Real Estate Settlement Procedures Act (“RESPA”), as implemented by Regulation X, 12 C.F.R. Part 1024, as set forth below:

a)Good Faith Estimate (GFE) (§1024.7) as applicable for loans with application dates prior to October 3, 2015:
i)confirm the presence of the current GFE form in effect at the time of origination;
ii)verify GFE was provided to the borrower(s) within three (3) business days of application;
iii)verify all sections of the GFE were accurately completed and that information was reflected in the appropriate locations;
iv)determine whether a valid and properly documented changed circumstance accompanies any changes to loan terms and/or fees on any revised GFEs over the applicable tolerance(s); and
v)confirm the presence of a settlement service provider list, as applicable.
b)Final HUD-1/A Settlement Statement (HUD) (§1024.8) as applicable for loans with application dates prior to October 3, 2015:
i)confirm current applicable HUD form was provided;
ii)determination that the loan file contains the final HUD;
iii)escrow deposit on the final HUD matches the initial escrow statement amount; and
iv)verify all sections of the final HUD were accurately completed and that information was reflected in the appropriate locations.
c)GFE and Final HUD Comparison (§1024.7) as applicable for loans with application dates prior to October 3, 2015:
i)review changes disclosed on the last GFE provided to the borrower(s) to determine that such changes were within the allowed tolerances;
ii)confirm loan terms and fees disclosed on the third page of the final HUD accurately reflect how such items were disclosed on the referenced GFE, page 2 of the final HUD and loan documents; and
iii)review any documented cure of a tolerance violation to determine that the proper reimbursement was made and a revised HUD was provided at or within 30 days of settlement.
d)Additional RESPA/Regulation X Disclosures and Requirements (§1024.6, 15, 17, 20, and 33):
i)confirm the presence of the Servicing Disclosure Statement form in the loan file;
ii)verify the Servicing Disclosure Statement was provided to the borrower(s) within three (3) business days of application;
iii)confirm the presence of the Special Information Booklet in the loan file or that the loan file contains documentary evidence that the disclosure was provided to the borrower;
iv)confirm the Special Information Booklet was provided within three (3) business days of application;
v)confirm the presence of the Affiliated Business Arrangement Disclosure in the loan file in the event the lender has affiliated business arrangements;
vi)confirm the Affiliated Business Arrangement Disclosure was provided no later than three (3) business days of application;
vii)confirm the Affiliated Business Arrangement Disclosure is executed; and
viii)confirm the presence of the Initial Escrow Disclosure Statement in the loan file and proper timing.

(III) The disclosure requirements and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution and associated regulations;

 

(IV) The disclosure requirements and prohibitions of state, county and municipal laws and ordinances with respect to “high-cost” loans, “covered” loans, “higher-priced” loans, “home” loans or any other similarly designated loan as defined under such authorities, or subject to any other laws that were enacted to combat predatory lending, as may have been amended from time to time;

 

(V) Federal and state specific late charge and prepayment penalty provisions;

 

(VI) Document Review

AMC reviewed each mortgage loan file and verified if the following documents, if applicable, for the Review scope in question at the time of review, were included in the file and if the data on these documents was consistent:

§Initial application (1003);
§Final application (1003);
§Note;
§Appraisal;

 

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§Sales contract;
§Title/Preliminary Title;
§Initial TIL;
§Final TIL;
§Final HUD-1;
§Initial and final GFE’s;
§Right of Rescission Disclosure;
§Mortgage/Deed of Trust;
§Mortgage Insurance;
§Tangible Net Benefit Disclosure;
§FACTA disclosures; and
§Certain other disclosures related to the enumerated tests set forth herein.

 

(8) Other: review and methodology.

 

Post-Acquisition Payment History Review

AMC performed a review utilizing a compiled monthly report provided by the Client of the contractual next due dates while the mortgage loans were serviced by BLS and contractual paid to dates while the mortgage loans were serviced by CFS using month-end cut-off in each case. Using the MBA methodology, AMC created a payment string using a 24 month look back for each mortgage loan within the payment history random sample population.  This payment history review was performed with information provided by the Client and utilizing the Clients’ instructions concerning the payment history calculation. During the review, AMC utilized either the contractual next due dates or the contractual paid to dates to which AMC was instructed to add a month to reflect the next due contractual paid to date, (together, the “next due dates”). After the next due date was compiled, AMC created a delinquency string based on that next due data and then compared that pay string to the one provided by the Client on the securitization tape.  AMC was not given additional information such as cash flow to confirm that a payment was made in any given month resulting in the interest paid to date or contractual next due date provided.  As such, AMC cannot confirm that the payment strings verified reflected payments actually being made on the mortgage loans versus the servicer advancing the interest paid to dates or contractual next due dates to reflect extensions, deferments or other payment holidays.

 

 

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SUMMARY OF FINDINGS & CONCLUSIONS OF REVIEW

There were 729 mortgage loans in the final compliance population as reviewed by AMC. After all documents were presented, 452 (62.00%) of the mortgage loans had compliance exceptions; however, only 75 (10.29%) of the mortgage loans had exceptions that triggered a C or D rating under the NRSRO rating criteria noted above.

 

COMPLIANCE RESULTS SUMMARY (729 Mortgage Loans)

Pursuant to the applicable NRSRO criteria, AMC graded certain compliance exceptions as non-material based upon seasoning of the mortgage loan. Certain mortgage loans were seasoned beyond the applicable period under TILA in which affirmative claims could be brought by a consumer. The time period is not limited for claims, other than rescission, which are raised as a defense to foreclosure. Information contained in any AMC report related to the applicable statute of limitations for certain claims may not be accurate or reflect the most recent controlling case law. Further, a particular court in a particular jurisdiction may extend, not enforce or otherwise allow claims beyond the statute of limitations identified in the report based on certain factors, including the facts and circumstances of an individual mortgage loan.

 

AMC Diligence, LLC (729 Mortgage Loans)

Compliance: Event Level Loan Count % of Loans
A 277 38.00%
B 377 51.71%
C 10 1.37%
D 65 8.92%
Total 729 100.00%

 

The following exceptions were noted on the mortgage loans included in the Compliance Review performed by AMCD. Only compliance EV3s, as noted when conducting the original review in question, are listed below. An EV3 may not result in a compliance C or D grade per relevant rating agency guidelines and some mortgage loans may have multiple exceptions. Certain RESPA and application date related exceptions, based upon the time of the initial review or client preference, may have originally been considered an EV3 and may be reported in the table below as such but would now be considered an EV2 or “B” per NRSRO guidelines. The # of Exceptions shown in the table below refers to the total number of exceptions which fell into that category and the % Loans is based solely on the # of Exceptions as a percentage of the total loans reviewed. However, it is possible that a single loan may have multiple exceptions within an Exception category.

 

Category Exception # of Exceptions % Loans
Compliance  TIL Right to Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form, or provided at the wrong time 95 13.03%
  TIL Finance Charge or APR Tolerance Non-Compliance 75 10.29%
  Missing, Incorrect, or Incomplete HUD-1 66 9.05%
  Federal Higher Priced Mortgage Loan and related exceptions 19 2.61%
  TIL- MDIA Non-Compliance 18 2.47%
  Other – Missing Data 13 1.78%
  Other TILA Violations 9 1.23%
  Missing, Incorrect or Incomplete TIL 9 1.23%
  Incomplete Loan Image 7 0.96%
  State Higher Priced Mortgage Loan and related exceptions 7 0.96%
  Missing Note 6 0.82%
  State Compliance – Late Charge Non-Compliant 4 0.55%
  State Compliant 1 0.14%
Total   329  

 

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DATA INTEGRITY REVIEW RESULTS SUMMARY (729 Mortgage Loans)

AMC compared data fields on the securitization tape provided by the Client to the data found in the actual file or in certain instances to other verification sources where data may have changed since the origination of the loan such as borrower last name changing due to marital status changes or address changing due to 911 address changes or Note address not reflecting a physical address. In total, 554 unique mortgage loans (75.99% of the total) were identified to have variances across twenty-nine (29) unique data fields (a total of 32 unique data fields were included in the Data Integrity Review). The largest variances were found on Current Maturity Date, Original Rate and Origination FICO.

 

During the course of the data integrity review, AMC noted the following items:

§Approximately half of the Current Maturity Date deltas are off by less than a full month indicating most likely that a change in the due date was approved at some point;
§Almost all (196 of 201) of the Original Interest Rate Deltas were off by less than 0.005 as it appeared that the Interest Rate per the securitization tape was rounded up to two decimal places;
§The Mod Loan Amount deltas appear to be due to the tape value reflecting total modification unpaid principal balance whereas the audited value reflects the accruing principal balance (excluding deferred amounts). The Client may have updated these values on the final securitization tape; and
§Most of the deltas for Original FICO, Property Type and Appraised Value were due to the data not being available in the file provided.

 

Data Field Primary Document # Deltas % Loans
CURRENT MATURITY DATE Latter of Note or Modification 292 40.05%
ORIGINAL RATE Note 201 27.57%
ORIGINAL FICO Credit Report or FACTA 175 24.01%
MOD LOAN AMOUNT Modification 78 10.70%
MOD DATE Modification 75 10.29%
APPRAISED VALUE Appraisal or other Property Information 73 10.01%
ORIGINAL P&I Note 45 6.17%
MOD FLAG Modification 43 5.90%
PROPERTY TYPE Appraisal or other Property Information 37 5.08%
MOD FIRST PAYMENT DATE Modification 35 4.80%
PROPERTY ZIP Note 18 2.47%
FIRST RATE ADJ DATE Latter of Note or Modification 12 1.65%
PROPERTY CITY Note 10 1.37%
FIRST PAYMENT ADJ DATE Latter of Note or Modification 9 1.23%
PROPERTY ADDRESS Note 9 1.23%
AMORTIZATION TYPE Latter of Note or Modification 6 0.82%
BALLOON FLAG Latter of Note or Modification 6 0.82%
NOTE DATE Note 6 0.82%
BORROWER LAST NAME Note 5 0.69%
ORIGINAL FIRST PAYMENT DATE Note 4 0.55%
LIEN POSITION Title documentation 3 0.41%
PURPOSE HUD, 1003 or 1008 (approval) 3 0.41%
ARM INDEX Latter of Note or Modification 2 0.27%
MARGIN Latter of Note or Modification 2 0.27%
MAX LIFE RATE Latter of Note or Modification 2 0.27%
MIN LIFE RATE Latter of Note or Modification 2 0.27%
PERIODIC CAP Latter of Note or Modification 2 0.27%
PERIODIC FLOOR Latter of Note or Modification 2 0.27%
RATE CHANGE FREQ Latter of Note or Modification 2 0.27%

 

 

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OTHER REVIEW RESULTS SUMMARY

 

POST ACQUISITION 24 MONTH PAYMENT HISTORY REVIEW (774 Loans)

Using the MBA methodology as applied based upon the scope defined above under Item 4(8), AMC created a payment string using a 24 month look back for each mortgage loan within the payment history random sample population. The results of this review are summarized below.

 

12 Month Lookback

Clean Pay During Lookback Loan Count % of Loans
Yes 772 99.74%
No 2 0.26%
Total 774 100.00%

 

24 Month Lookback

Clean Pay During Lookback Loan Count % of Loans
Yes 750 96.90%
No 24 3.10%
Total 774 100.00%

 

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Loan Level Exception - Disposition (Loan Grades)

Run Date - 4/11/2017 6:10:00 PM

AMC Loan ID 2017-SPL3 ID State Occupancy Purpose QM Status Overall Grade Credit Grade Credit Exceptions Credit Exception Information Credit Exception Comments Compliance Grade Compliance Exceptions Compliance Exception Information Compliance Exception Comments Compliance Factors Subject to Predatory -
Unable to Test
Disposition 2 Fitch

Compliance
Grade
DBRS
Compliance
Grade
Seasoning >
3 Years
Subject to
Predatory
Lending
Section 32
Flag
HOEPA
High Cost
Loan
State High
Cost Loan
200367305 2017SPL3100027 WV Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200367313 2017SPL3100002 WI Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200367358 2017SPL3100004 NC Primary Refinance Cash-out - Debt Consolidation   1 1       1           - A A Yes Yes No No No
200367362 2017SPL3100019 PA Primary Refinance Cash-out - Debt Consolidation   1 1       1           - A A Yes Yes No No No
200367386 2017SPL3100009 FL Primary Refinance Cash-out - Debt Consolidation   1 1       1           - A A Yes Yes No No No
200367394 2017SPL3100013 FL Primary Refinance Cash-out - Other   3 3 [3] Closing / Title - Title: Evidence of title is missing Missing initial and final title work.   3 [3] Closing / Title - Missing Final HUD-1: Missing Final HUD-1.  No document containing fees provided.  Any applicable Federal, State or Local compliance testing is unreliable.
[3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions. Yes TR Indeterminable D D Yes Yes No No N/A
200367414 2017SPL3100026 AZ Primary Refinance Rate/Term   1 1       1             A A Yes Yes No No N/A
200367430 2017SPL3100001 FL Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200367452 2017SPL3100007 OK Primary Refinance   3 3 [3] Miscellaneous Compliance - Missing Document: Service Provider Disclosure not provided     3 [3] Loan File - (Missing Doc) Incomplete loan images/file
[3] Miscellaneous Compliance - Missing Document: Right to Cancel (RTC) not provided
[3] Federal Compliance - Missing Final HUD-1
Missing Refi purpose   TILA ROR - 3yrs for rescindable transactions. UTD Indeterminable D D Yes UTD   N/A N/A
200367489 2017SPL3100010 ME Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200367495 2017SPL3100005 PA Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200367498 2017SPL3100011 NY Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.         - B B Yes Yes No No No
200367500 2017SPL3100024 OK Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $96328.82 is underdisclosed from calculated Finance Charge of $96370.88 in the amount of $42.06.
[3] Federal Compliance - TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date: Truth in Lending Act:  Actual Date(s) on Notice of Right to Rescind occurs prior to expected date(s).
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Final TIL dated 12/15/99 but not executed by the borrower until 12/16/99.
Confirmed the TIL Finance Charges on Note and Final TIL.
  TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

TILA ROR - 3yrs for rescindable transactions.
  TILA SOL Expired B B Yes Yes No No N/A
200367541 2017SPL3100015 LA Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.         - B B Yes Yes No No N/A
200367580 2017SPL3100022 NM Primary Refinance Cash-out - Debt Consolidation   1 1       1           - A A Yes Yes No No N/A
200367633 2017SPL3100017 WV Primary Refinance Cash-out - Other   2 1       2 [2] 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.           B B Yes Yes No No N/A
200367639 2017SPL3100018 AL Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions.   TILA SOL Expired B B Yes Yes No No N/A
200367646 2017SPL3100023 VA Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $150925.86 is underdisclosed from calculated Finance Charge of $150996.56 in the amount of $70.70.
[2] State Compliance - (Doc Error) Note Error: Loan does not comply with state prepayment penalty requirements
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No N/A
200367687 2017SPL3100031 CA Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200367719 2017SPL3100021 CA Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No N/A
200367723 2017SPL3100040 NM Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200367726 2017SPL3100016 OK Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 2, 3, 5, 7, 8, 9, 10 or DC): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used.
[2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.   TILA SOL Expired B B Yes Yes No No No
200367728 2017SPL3100034 CT Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.           B B Yes Yes No No No
200367741 2017SPL3100014 NC Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
The loans being paid off at closing are to Commercial Credit Loans, Inc. and Beneficial Mortgage Co. of North Carolina.   TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.   TILA SOL Expired B B Yes Yes No No No
200367754 2017SPL3100029 CO Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No N/A
200367781 2017SPL3100045 LA Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $66106.33 is underdisclosed from calculated Finance Charge of $66281.34 in the amount of $175.01.
[2] 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.
    TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No N/A
200367796 2017SPL3100028 AL Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200367811 2017SPL3100032 NY Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200367818 2017SPL3103576 AL Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200367827 2017SPL3100053 CA Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200367831 2017SPL3100043 IA Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No N/A
200367835 2017SPL3100038 MI Primary Refinance Cash-out - Other   2 1       2 [2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower at the time of application.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower at the time of application.
          B B Yes Yes No No N/A
200367837 2017SPL3100044 KS Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200367892 2017SPL3100036 CT Primary Refinance Rate/Term   3 1       3 [3] Closing / Title - Missing Final HUD-1: Missing Final HUD-1.  No document containing fees provided.  Any applicable Federal, State or Local compliance testing is unreliable.
[3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions. Yes TR Indeterminable D D Yes Yes No No No
200367912 2017SPL3100046 AL Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on 3/30/2006 12:00:00 AM, prior to three (3) business days from transaction date of 3/30/2006 12:00:00 AM.
[3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions.

TILA ROR - 3yrs for rescindable transactions.
  TILA SOL Expired B B Yes Yes No No N/A
200367917 2017SPL3100039 KS Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No N/A
200367950 2017SPL3100062 NJ Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200367966 2017SPL3100030 NC Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $82088.46 is underdisclosed from calculated Finance Charge of $82139.86 in the amount of $51.40.     TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No No
200367980 2017SPL3100042 OH Primary Refinance Rate/Term   3 3 [3] Closing / Title - Title: Evidence of title is missing Title not provided   2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] State Compliance - Ohio Consumer Sales Practices Act (Acknowledgement of Receipt of Home Mortgage Loan Information Document Not Retained by Lender): Ohio Consumer Sales Practices Act: Acknowledgement of Receipt of Home Mortgage Loan Information Document not retained by lender.
[2] State Compliance - Ohio Consumer Sales Practices Act (Closing Disclosure Not Provided): Ohio Consumer Sales Practices Act:  Consumer did not receive the required Closing Disclosure.
[2] State Compliance - Ohio Consumer Sales Practices Act (No Tangible Net Benefit): Ohio Consumer Sales Practices Act: Mortgage loan refinanced does not have a tangible net benefit to the borrower.
        - B B Yes Yes No No No
200367989 2017SPL3100033 WV Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200367995 2017SPL3100047 TN Primary Refinance Cash-out - Debt Consolidation   3 3 [3] Missing Document - Title: Evidence of title is missing     2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200368001 2017SPL3100055 NC Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200368030 2017SPL3100037 SC Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $47398.17 is underdisclosed from calculated Finance Charge of $47491.38 in the amount of $93.21.
[2] State Compliance - South Carolina Home Loan (Complaint Agency Disclosure Not Provided): South Carolina Home Loan: Borrower not provided with a document, at time of application, specifying the agency designated to receive complaints or inquiries about the origination and making of the loan.
Refinance, seasoned >3 years, Lender did not include attorney fees in finance charges   Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to the potential remedies available to a court, this exception carries elevated risk to an assignee during the initial 6 years after occurrence of the violation. After the expiration of this 6 year period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same level as during the initial 6 years for affirmative claims.

TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
  TILA SOL Expired B B Yes Yes No No No
200368037 2017SPL3100054 NC Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $126882.73 is underdisclosed from calculated Finance Charge of $126949.31 in the amount of $66.58.
[2] Miscellaneous Compliance - (Doc Error) GFE Error: There is no evidence that the interest rate was locked prior to closing
[2] 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] Federal Compliance - RESPA (2010) -  Interest Rate on GFE Inaccurate: RESPA (2010): Interest Rate on GFE does not match Note.
[2] Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (2010): Loan Amount on Final GFE does not match Note.
[2] Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (2010): Initial payment on GFE does not match actual payment on loan.
[2] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 1, 4, 6, or 11): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)
Unable to determine rate lock; rate lock agreement not provided in loan file.   TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
  TILA SOL Expired B B Yes Yes No No No
200368065 2017SPL3100041 PA Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200368126 2017SPL3100035 FL Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200368140 2017SPL3100049 WI Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 2, 3, 5, 7, 8, 9, 10 or DC): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.   TILA SOL Expired B B Yes Yes No No N/A
200368146 2017SPL3100074 WA Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200368174 2017SPL3100080 NY Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.           B B Yes Yes No No No
200368189 2017SPL3100058 KY Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200368230 2017SPL3100063 IA Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200368244 2017SPL3100075 FL Primary Refinance Cash-out - Debt Consolidation   1 1       1           - A A Yes Yes No No N/A
200368250 2017SPL3103577 NC Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.           B B Yes Yes No No No
200368267 2017SPL3100048 RI Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200368276 2017SPL3100066 FL Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
        - B B Yes Yes No No No
200368301 2017SPL3100082 FL Primary Refinance Cash-out - Other   3 3 [3] Closing / Title - Title: Evidence of title is missing File does not contain either Preliminary or Final Title.   3 [3] Closing / Title - Missing Final HUD-1: Missing Final HUD-1.  No document containing fees provided.  Any applicable Federal, State or Local compliance testing is unreliable.
[3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions. Yes TR Indeterminable D D Yes Yes No No No
200368316 2017SPL3100064 WI Primary Refinance Cash-out - Other   2 1       2 [2] 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.           B B Yes Yes No No No
200368319 2017SPL3100067 NM Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200368321 2017SPL3100052 FL Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] 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.
          B B Yes Yes No No No
200368365 2017SPL3100065 IL Primary Refinance Cash-out - Other   1 1       1           - A A Yes Yes No No No
200368379 2017SPL3100050 PA Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200368460 2017SPL3100061 NC Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $153776.78 is underdisclosed from calculated Finance Charge of $153833.32 in the amount of $56.54.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
Under disclosure due to daily simple interest of $61.20 for life of loan.   TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No No
200368553 2017SPL3100073 NY Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $149084.50 is underdisclosed from calculated Finance Charge of $149164.90 in the amount of $80.40.     TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No No
200368577 2017SPL3100078 WV Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200368601 2017SPL3100083 SC Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $35358.10 is underdisclosed from calculated Finance Charge of $35508.09 in the amount of $149.99. Finance Charges under disclosed by $149.99.Lender did not include $150.00 Attorney's Fee from HUD in TIL Finance calculations.   TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No No
200368602 2017SPL3100089 VA Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - 2011 TIL-MDIA - Interest Rate Inaccurate: Truth in Lending Act (MDIA 2011): Interest rate on the Final TIL does not match interest rate for the loan.
[2] Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (2010): Loan Amount on Final GFE does not match Note.
[2] Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (2010): Initial payment on GFE does not match actual payment on loan.
[2] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 1, 4, 6, or 11): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)
[2] State Compliance - Virginia Mortgage Lender and Broker Act (Collateral Secured by Personal Property): Virginia Mortgage Lender and Broker Act:  Collateral securing the mortgage loan is other than real estate or residential property.
Collateral is real estate   TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
  TILA SOL Expired B B Yes Yes No No N/A
200368603 2017SPL3100079 TN Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] 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.
        - B B Yes Yes No No N/A
200368613 2017SPL3100068 ID Primary Refinance Cash-out - Home Improvement   3 1       3 [3] Federal Compliance - TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date: Truth in Lending Act:  Actual Date(s) on Notice of Right to Rescind occurs prior to expected date(s).     TILA ROR - 3yrs for rescindable transactions.   TILA SOL Expired B B Yes Yes No No N/A
200368620 2017SPL3100084 SC Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] 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] 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.
        - B B Yes Yes No No N/A
200368643 2017SPL3100109 GA Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.           B B Yes Yes No No No
200368660 2017SPL3100070 WI Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200368677 2017SPL3103578 PA Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200368681 2017SPL3100090 TN Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200368687 2017SPL3100069 OH Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No N/A
200368690 2017SPL3100071 SC Primary Refinance Cash-out - Other   2 1       2 [2] 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] 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.
    Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to the potential remedies available to a court, this exception carries elevated risk to an assignee during the initial 6 years after occurrence of the violation. After the expiration of this 6 year period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same level as during the initial 6 years for affirmative claims.   - B B Yes Yes No No No
200368708 2017SPL3100093 KY Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200368715 2017SPL3100087 CA Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200368753 2017SPL3100119 KY Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 1, 4, 6, or 11): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)
    TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.   - B B Yes Yes No No No
200368782 2017SPL3100076 IN Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200368795 2017SPL3100097 AL Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions.   TILA SOL Expired B B Yes Yes No No N/A
200368845 2017SPL3100086 NY Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200368847 2017SPL3100099 TN Primary Refinance Cash-out - Debt Consolidation   3 3 [3] Missing Document - Title: Evidence of title is missing     2 [2] 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.           B B Yes Yes No No N/A
200368898 2017SPL3100128 AZ Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200368902 2017SPL3100120 CT Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $353620.82 is underdisclosed from calculated Finance Charge of $353680.84 in the amount of $60.02.
[3] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on 2/3/2006 12:00:00 AM, prior to three (3) business days from transaction date of 2/3/2006 12:00:00 AM.
[3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

TILA ROR - 3yrs for rescindable transactions.

TILA ROR - 3yrs for rescindable transactions.
  TILA SOL Expired B B Yes Yes No No No
200368932 2017SPL3100126 WV Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200368940 2017SPL3100091 ID Primary Refinance Cash-out - Other   2 1       2 [2] State Compliance - Idaho Residential Mortgage Practices Act (Rate Lock Agreement Not Provided): Idaho Residential Mortgage Practices Act: Lock-in Agreement not provided to borrower.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
        - B B Yes Yes No No N/A
200368947 2017SPL3100116 CO Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] State Compliance - Colorado Consumer Credit Code (First Lien Refinance Notice Not Provided): Colorado Consumer Credit Code: Borrower not provided First Lien Refinance Notice.     Assignee Liability:  For a transaction involving a security interest in land, any action that may be brought against the original creditor may be maintained against any subsequent assignee where the assignee, its subsidiaries, or affiliates were in a continuing business relationship with the original creditor either at the time the credit was extended or at the time of the assignment unless the assignment was involuntary or the assignee shows by a preponderance of evidence that it did not have reasonable grounds to believe that the original creditor was engaged in violations of the code and that it maintained procedures reasonably adapted to apprise it of the existence of the violations.     B B Yes Yes No No No
200368982 2017SPL3100127 WV Primary Refinance Cash-out - Other   2 1       2 [2] 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.           B B Yes Yes No No N/A
200369031 2017SPL3100107 NC Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.           B B Yes Yes No No No
200369053 2017SPL3100096 AL Primary Refinance Cash-out - Other   1 1       1           - A A Yes Yes No No N/A
200369061 2017SPL3100146 MI Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] 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.
        - B B Yes Yes No No N/A
200369063 2017SPL3100121 WV Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200369072 2017SPL3100092 SC Primary Refinance Cash-out - Other   3 1       3 [3] Closing / Title - Missing Final HUD-1: Missing Final HUD-1.  No document containing fees provided.  Any applicable Federal, State or Local compliance testing is unreliable.
[3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions. Yes TR Indeterminable D D Yes Yes No No N/A
200369085 2017SPL3100088 FL Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200369087 2017SPL3100144 ND Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] 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.
        - B B Yes Yes No No N/A
200369149 2017SPL3103579 LA Primary Refinance Cash-out - Other   2 1       2 [2] 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.           B B Yes Yes No No N/A
200369179 2017SPL3100145 CA Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200369189 2017SPL3100105 CA Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions.   TILA SOL Expired B B Yes Yes No No No
200369197 2017SPL3100095 NY Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200369231 2017SPL3100104 AL Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $86666.84 is underdisclosed from calculated Finance Charge of $86707.42 in the amount of $40.58.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No N/A
200369233 2017SPL3100134 MS Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200369296 2017SPL3100122 NY Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - 2011 TIL-MDIA - Interest Rate Inaccurate: Truth in Lending Act (MDIA 2011): Interest rate on the Final TIL does not match interest rate for the loan.
[2] Miscellaneous Compliance - (Doc Error) GFE Error: There is no evidence that the interest rate was locked prior to closing
[2] Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (2010): Loan Amount on Final GFE does not match Note.
[2] Federal Compliance - RESPA (2010) -  Interest Rate on Final HUD-1 Inaccurate: RESPA (2010): Interest Rate on Final HUD-1 does not match Note.
[2] Federal Compliance - RESPA (2010) – Written Service Provider List Missing: RESPA (2010):  Borrower not provided with list of service providers.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to borrower.
Interest rate per note 10.10.  Interest rate on TIL 10.0968   TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No No
200369301 2017SPL3100100 FL Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $192513.34 is underdisclosed from calculated Finance Charge of $192603.46 in the amount of $90.12.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No No
200369314 2017SPL3100123 CA Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - FACTA Disclosure Not Provided Prior to Closing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] 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.
        - B B Yes Yes No No No
200369333 2017SPL3100114 MS Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on 10/23/2007 12:00:00 AM, prior to three (3) business days from transaction date of 10/19/2007 12:00:00 AM.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] 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.
    TILA ROR - 3yrs for rescindable transactions.   TILA SOL Expired B B Yes Yes No No N/A
200369343 2017SPL3100140 GA Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200369344 2017SPL3100125 OK Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200369408 2017SPL3100147 MO Primary Refinance Cash-out - Debt Consolidation   1 1       1           - A A Yes Yes No No N/A
200369425 2017SPL3100111 WV Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No N/A
200369431 2017SPL3100124 FL Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 1, 4, 6, or 11): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)     TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.     B B Yes Yes No No No
200369439 2017SPL3100148 NC Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200369442 2017SPL3100113 TN Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200369458 2017SPL3100139 WV Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200369460 2017SPL3100151 AL Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
        - B B Yes Yes No No N/A
200369472 2017SPL3100132 GA Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200369490 2017SPL3100149 OH Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200369520 2017SPL3100150 CA Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on 2/20/2001 12:00:00 AM, prior to three (3) business days from transaction date of 2/15/2001 12:00:00 AM.
[3] Federal Compliance - TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date: Truth in Lending Act:  Actual Date(s) on Notice of Right to Rescind occurs prior to expected date(s).
    TILA ROR - 3yrs for rescindable transactions.

TILA ROR - 3yrs for rescindable transactions.
  TILA SOL Expired B B Yes Yes No No N/A
200369538 2017SPL3100133 MN Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Federal FACTA Disclosure: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Minnesota Residential Mortgage Originator and Servicer Licensing Act (Ability to Repay not Verified): Minnesota Residential Mortgage Originator and Servicer Licensing Act: Borrower's ability to repay was not verified.
No evidence to support ability to repay was located in file.       - B B Yes Yes No No N/A
200369611 2017SPL3100106 WI Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200369625 2017SPL3100117 MS Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 2, 3, 5, 7, 8, 9, 10 or DC): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.   TILA SOL Expired B B Yes Yes No No N/A
200369684 2017SPL3100158 FL Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200369690 2017SPL3100108 CA Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No No
200369704 2017SPL3100160 TN Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200369713 2017SPL3100118 WI Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200369714 2017SPL3100156 AL Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200369720 2017SPL3100157 AL Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA ROR - 3yrs for rescindable transactions.   TILA SOL Expired B B Yes Yes No No N/A
200369722 2017SPL3100155 WI Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200369753 2017SPL3100159 OH Primary Refinance Cash-out - Other   3 1       3 [3] Federal Compliance - TIL-MDIA 7-day Waiting Period - Initial TIL Less than 7 days from Consummation: Truth in Lending Act (Early TIL Disclosure):  Initial TIL was not delivered to the borrower at least seven (7) business days prior to note date.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] State Compliance - Ohio Consumer Sales Practices Act (No Documentation of Tangible Net Benefit Analysis): Ohio Consumer Sales Practices Act:  Mortgage loan file does not contain documentation of the analysis of the borrower's reasonable tangible net benefit.
[2] 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.
    TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No No
200369763 2017SPL3100129 NC Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 1, 4, 6, or 11): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used. (The property state is in the 1st, 4th, 6th, or 11th circuit.)     TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.     B B Yes Yes No No No
200369764 2017SPL3100152 CA Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] 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.           B B Yes Yes No No No
200369783 2017SPL3100112 NC Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200369799 2017SPL3100154 AL Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No N/A
200369805 2017SPL3100115 WV Primary Refinance Cash-out - Debt Consolidation   1 1       1             A A Yes Yes No No N/A
200369900 2017SPL3100137 AZ Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 2, 3, 5, 7, 8, 9, 10 or DC): Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinancing by the same creditor. The H-8 form was used, the H-9 form should have been used.     TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.   TILA SOL Expired B B Yes Yes No No N/A
200370043 2017SPL3100142 OH Primary Refinance Cash-out - Other   1 1       1             A A Yes Yes No No No
200370045 2017SPL3100135 NC Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200370057 2017SPL3100166 FL Primary Refinance Cash-out - Debt Consolidation   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
[2] 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.
        - B B Yes Yes No No No
200370110 2017SPL3100165 NC Primary Refinance Cash-out - Debt Consolidation   3 1       3 [3] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act:  Final TIL Finance Charge of $94345.38 is underdisclosed from calculated Finance Charge of $94387.09 in the amount of $41.71.
[2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.
    TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.   TILA SOL Expired B B Yes Yes No No No
200370126 2017SPL3100163 FL Primary Refinance Cash-out - Other   2 1       2 [2] Federal Compliance - Initial Loan Application Status Test: No evidence of application date located in file.  Compliance tests were run using a 7 month lookback from the consummation date.         - B B Yes Yes No No No
200370229 2017SPL3100141 GA Primary