ABS-15G

OMB Number: [3235-0675]

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM ABS-15G

ASSET-BACKED SECURITIZER
REPORT PURSUANT TO SECTION 15G OF
THE SECURITIES EXCHANGE ACT OF 1934

HOF I 2019-3 DEPOSITOR LLC

Check the appropriate box to indicate the filing obligation to which this form is intended to satisfy:

____ Rule 15Ga-1 under the Exchange Act (17 CFR 240.15Ga-1) for the reporting period______________ to _________________

Date of Report (Date of filing) __________________

Commission File Number of securitizer: __________________

Central Index Key Number of securitizer:__________________

Name and telephone number, including area code, of the person
to contact in connection with this filing.

Indicate by check mark whether the securitizer has no activity to report for the initial period pursuant to Rule 15Ga-1(c)(l) [ ]

Indicate by check mark whether the securitizer has no activity to report for the quarterly period pursuant to Rule 15Ga-1(c)(2)(i) [ ]

Indicate by check mark whether the securitizer has no activity to report for the annual period pursuant to Rule 15Ga-1(c)(2)(ii) [ ]

   X   Rule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2)

Central Index Key Number of depositor: 0001789627

HOMEWARD OPPORTUNITIES FUND I TRUST 2019-3

(Exact name of issuing entity as specified in its charter)

Central Index Key Number of issuing entity (if applicable): Not applicable

Central Index Key Number of underwriter (if applicable): Not applicable

Dmitry Gasinsky, 312-879-8433

Name and telephone number, including area code, of the person
to contact in connection with this filing.

FINDINGS AND CONCLUSIONS OF THIRD-PARTY DUE DILIGENCE REPORTS

Item 2.01 Findings and Conclusions of a Third Party Due Diligence Report Obtained by the Issuer

The disclosures required by Rule 15Ga-2 (17 CFR 240.15Ga-2) are attached as Exhibits to this Form ABS-15G. Please see the Exhibit Index for the related information.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the reporting entity has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

	HOF I 2019-3 DEPOSITOR LLC
Date: November 14, 2019	By:	/s/ Dmitry Gasinsky
	Name:	Dmitry Gasinsky
	Title:	Chief Executive Officer

EXHIBIT INDEX

Exhibit Number

99.1       Third Party Due Diligence Report - EdgeMac Executive Summary

Schedule 1 - Exception Report

Schedule 2 - Rating Agency Grades Report

Schedule 3 - Final Tape Compare Report

Schedule 4 - Valuation Summary Report

99.2       Third Party Due Diligence Report - Clayton Executive Summary

Schedule 1 - Conditions Report

Schedule 2 - Loan Level Tape Compare Report

Schedule 3 - Non ATR QM Upload Report

Schedule 4 - Rating Agency ATR QM Data Fields Report

Schedule 5 - Valuations Summary Report

99.3       Third Party Due Diligence Report - AMC Executive Summary

Schedule 1 - Rating Agency Grades Report

Schedule 2 - Exception Grades Report

Schedule 3 - Valuation Summary Report

Schedule 4 - Data Compare Report

99.4       Third Party Due Diligence Report - Opus Executive Summary

Schedule 1 - ATR Report

Schedule 2 - Data Compare Report

Schedule 3 - Exception Report

Schedule 4 - Grading Summary Report

Schedule 5 - Valuation Report

EX-99.1

Exhibit 99.1

EXECUTIVE SUMMARY

HOF 2019-3

Description of the due diligence performed

Overview of the assets that were reviewed

Edge Mortgage Advisory Company, LLC (“EdgeMAC”) performed an independent third-party due diligence review of 131 loans acquired by Sprout Mortgage Corporation (the “Client”). The review was performed between February 2019 through October 2019.

Sampling of assets

EdgeMAC follows the nationally recognized statistical rating organizations, NRSRO(s), criteria. For all originators, EdgeMAC, LLC performed review on 100% of the loans. The loan population was 131 loans for an aggregate principal balance of $41,030,434.00.

The review was conducted in accordance with the following NRSRO(s) Third Party Due Diligence Criteria:

Identity of NRSRO	Title and Date of Criteria
S&P Global Ratings	Methodology And Assumptions For Rating U.S. RMBS Issued 2009 and Later, February 22, 2018
DBRS, Inc.	Third-Party Due Diligence Criteria for U.S. RMBS Transactions, September 2017

Data integrity and methodology

EdgeMAC performed data integrity analysis on all loans in the sample by comparing the information supplied on the data tape against the source documents in the loan file. All discrepancies are reported on the Final Tape Compare Report.

The data comparison consisted of the following data fields:

Data Comparison Fields

Amortization Term

Appraisal Value

Borrower First Name

Borrower Last Name

Borrower Self-Employed

Borrower SSN

Co Borrower 1 Self-Employed

Co-Borrower 1 SSN

Coborrower 1 First Name

Coborrower 1 Last Name

Doc Type

First Payment Date

First Rate Adjustment Date

FTHB Flag

Initial Rate Adjustment Period

Interest Only Flag

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Interest Only Months

Interest Rate Initial Cap

Interest Rate Life Cap

Interest Rate Life Ceiling

Interest Rate Periodic Cap

Interest Rate Rate Change Frequency

Interset Rate Life Floor

Investor Qualifying DSCR

Investor Qualifying DTI

Lien Position

Loan Purpose

Loan Type

Margin

Maturity Date

MERS Min Number

Note Date

Number of Units

Occupancy Type

Original CLTV

Original Interest Rate

Original Loan Amount

Original LTV

Original P&I

Original Term

Prepayment Flag

Prepayment Term

Property City

Property State

Property Street Address

Property Type

Property Zip

QM Designation

Qualifying Credit Score

Sales Price

Underwriting Conformity

EdgeMAC performed a complete review of all loan files, as supplied by the Client, to determine whether the loans were originated in accordance with the Client’s underwriting guidelines, eligibility requirements, Ability to Repay (ATR), Qualified Mortgage and Appendix Q requirements (where applicable), and applicable Policies & Procedures, noting any exceptions and compensating factors. The review included, where applicable, the following items:

Conformance to Ability to Repay (ATR) standards – EdgeMAC reviewed each loan to validate that the underwriter correctly assessed the borrower’s ability to repay based on employment and credit/repayment history, income and assets, projected monthly payment and current obligations, debt to income ratio, and other information provided to support ability to repay prior to originating the loan.

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An evaluation of Qualified Mortgage and Appendix Q requirements, if applicable – Based on the information provided, EdgeMAC will review each loan to determine that it satisfies all requirements for a Qualified Mortgage, if designated as such, including an evaluation of points of fees, risk factors associated with the loan terms, re-calculation of debt to income and a review of all income and assets.

Credit, Income, Assets and Employment

A. Validate that the appropriate employment and income documentation, such as pay stubs, tax transcripts, and bank statements, was provided and used to accurately qualify the borrower according to guidelines. Recalculate the borrower’s income and debt to determine the appropriate debt to income ratio in accordance with the guidelines. Validate borrower’s employment history and confirm that the appropriate income and assets were used to qualify, where applicable. Make a reasonable assessment of whether there are any indications that income documentation may be fraudulent.

B. Validate that assets used to qualify the borrower match the documentation in the file and the information used to calculate down payment, closing costs, and reserves meet program guideline requirements.

C. Review exceptions, compensating factors and underwriter comments, if available.

D. Review program guidelines against the loan approval for discrepancies such as:

1. Employment requirements;

2. Income requirements (such as DTI, etc);

3. Asset requirements

E. Review the loan approval against all supporting documentation and loan application to verify accuracy

F. Review the initial loan application against the final loan application or other loan applications found in the file to validate the application was signed, properly completed and to expose discrepancies.

G. Confirm that credit report(s) and verification of mortgage or rental history, when required, have been provided for all borrowers/guarantors, are consistent with loan approval, and meet guideline requirements. Verify whether any fraud alerts are listed on the credit reports and make a reasonable assessment of whether the borrower’s profile adheres to applicable guidelines.

H. Review the loan file for inconsistencies based on information derived from source documentation provided in the loan file, for the purposes of identifying misrepresentations contained in the loan file, including with respect to occupancy and mortgage liabilities.

Occupancy, Taxes, Title and Insurance

A. Review source documents for consistency with regard to subject property occupancy intent.

B. Review the title report for possible judgments and other liens that may have existed upon origination; verify chain of title, as required by guidelines.

C. Verify and validate the file contains sufficient property insurance coverage as required by guidelines; confirm property insurance policy contains appropriate mortgagee clause. For subject properties located in a Special Flood Hazard Area where flood insurance is required, verify and validate the file contains sufficient flood insurance coverage as required by guidelines and that flood insurance policy contains appropriate mortgagee clause.

D. Review property details on appraisal including a review for ineligible properties.

E. Verify that Business Purpose Affidavit and Occupancy Affidavit, if applicable, were executed by the borrowers/guarantors and confirm that document addresses are consistent with subject property address and do not match the primary residence address.

Property Valuation Review

EdgeMAC performed a standard property valuation Desktop Review on all loans to ensure the original property valuation in the loan file supports the subject property and to determine whether there are any indicators of misrepresentation. The evaluation included the following components:

A. Review the original appraisal report to ensure the valuation was performed by a licensed appraiser and in accordance with guidelines,

B. Verify subject property type meets applicable guidelines,

C. Validate that the values used do not exceed 6 months in age,

D. Note any exceptions to stated value or appraisal guidelines,

E. Verify value used to calculate LTV/CLTV and note any deviations,

F. Verify the appraisal report matches loan documents, and

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G. Review additional valuation products in the file; if there is a 10% variance, Client is notified and an additional independent valuation product will be obtained.

Regulatory Compliance Review

EdgeMAC’s Regulatory Compliance analysis is intended to expose certain potential risk associated with the loans examined. It is strictly limited to the review scope outlined below and is based solely on the accuracy of the documentation and data supplied by the Client or other agreed upon third parties. The review findings are not guaranteed to encompass all critical elements related to the underwriting, origination or regulatory compliance status of the loans examined. Further, the findings are not to be construed as guidance on future indicators of positive or negative performance.

EdgeMAC performed a review of all loans supplied by the Client to verify all documentation provided is complete and complies with all applicable federal and state regulatory requirements, in addition to following the RMBS 3.0 TRID Compliance Review Scope published by the Structured Finance Industry Group (the “SFIG Compliance Review Scope”) and the advice of outside counsel. In addition, EdgeMAC utilizes the ComplianceAnalyzer tool by ComplianceEase. EdgeMAC’s conclusions are representative of our best efforts to identify material risks and exceptions associated with each loan based on interpretation of the continually evolving regulations.

EdgeMAC does not employ personnel who are licensed to practice law in the various jurisdictions and the findings set forth in the reports prepared by EdgeMAC do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to EdgeMAC. All final decisions as to whether to purchase or enter into a transaction related to any individual loan or the loans in the aggregate and any legal conclusions, including the potential liability related to the purchase or other transaction involving any such loan or loans, shall be made solely by the clients that have engaged EdgeMAC to prepare their reports pursuant to their instructions and guidelines. Client acknowledges and agrees that the scoring models applied by EdgeMAC are designed to identify potential risk and the Client assumes sole responsibility for determining the suitability of the information for its particular use.

EdgeMAC reviewed each loan to validate compliance with the following federal and state regulatory requirements, whenever applicable.

A. Truth In Lending Act - 12 CFR §1026 (“TILA”)

1. Federal TILA

a. Finance Charge Test (12 CFR §1026.18(d)(1)

i. It is understated by no more than $100; or

ii. It is greater than the amount required to be disclosed

b. Rescission Finance Charge Test (12 CFR §1026.23(h)(2)i)

i. It is understated by no more than $35; or

ii. It is greater than the amount required to be disclosed

iii. Rescission Total of Payments Test (12 CFR §1026.23(h)(2)(ii)

iv. Is understated by no more than $35; or

v. Is greater than the amount required to be disclosed

c. Foreclosure Rescission Finance Charge and Total of Payments Tests(12 CFR §1026.23(h)

d. APR Test 12 CFR §1026.22(a)(2), (4)

i. The disclosed annual percentage rate (APR) is considered accurate because it is not more than 1/8 of 1 percentage (for regular transactions) or 1/4 of 1 percentage (for irregular transactions) point above or below the APR as determined in accordance with the actuarial method; or

ii. The disclosed APR results from the disclosed finance charge, and the disclosed finance charge is considered accurate under §1026.18(d)(1) (the finance charge test), or for purposes of rescission the disclosed finance charge is considered accurate under §1026.23(g) or (h) (the rescission finance charge test or the foreclosure rescission finance charge test), whichever applies

e. Right of Rescission Test (12 CFR §1026.23(a)(3), §1026.15(a)(3),

i. The funding date is not before the third business day following consummation

ii. The consumer may exercise the right to rescind until midnight of the third business day following consummation

iii. Validate Right of Rescission Notice was provided and provides the correct date for ability to cancel

f. Dual Broker Compensation Test (12 CFR §1026.36(d)(2)

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i. If any loan originator receives compensation directly from a consumer in a consumer credit transaction secured by a dwelling, no loan originator shall receive compensation, directly or indirectly, from any other person other than the consumer in connection with the transaction for loan origination activities

g. Loan Originator Credits Test (12 C.F.R. §1026.36(d)(1))

i. Test that the initial disclosure (GFE/TIL/LE) does not contain any broker fees paid by the broker

h. Financing of Single Premium Credit Insurance Test (12 CFR §1026.36 (i))

i. A creditor may not finance, directly or indirectly, any premiums or fees for credit insurance in connection with a consumer credit transaction secured by a dwelling (including a home equity line of credit secured by the consumer's principal dwelling

2. Initial TIL Disclosure (Pre-TRID)

a. Initial TIL Disclosure Date Test (12 CFR §1026.17(b),1026.19(a)

i. The loan is a mortgage transaction subject to the Real Estate Settlement Procedures Act (12 U.S.C. §2601 et seq.) that is secured by the consumer's dwelling; and

ii. The initial TIL disclosure date is not later than the third business day (counting days on which the creditor's offices are open to the public for carrying on substantially all of its business functions) after the creditor receives the consumer's written application; and

iii. The initial TIL disclosure date is not later than the seventh business day (counting all calendar days except Sunday and specified legal public holidays) before consummation of the transaction, or the application date of the loan is before July 30, 2009; and

iv. The loan is a "residential mortgage transaction" subject to the Real Estate Settlement Procedures Act (12 U.S.C. §2601 et seq.); and

v. The initial TIL disclosure date is before consummation or three business days after the creditor receives the consumer's written application, whichever is earlier

3. TILA RESPA Integrated Disclosures (TRID)

a. Initial Loan Estimate Delivery Date Test (from application) (12 CFR §1026.19(e)(1)(iii)(A))

i. The creditor shall deliver or place in the mail the disclosures required under §1026.19(e)(1)(i) (provision of loan estimate form) not later than the third business day after the creditor receives the consumer's application

b. Initial Loan Estimate Delivery Date Test (prior to consummation) (12 CFR §1026.19(e)(1)(iii)(B))

i. The creditor shall deliver or place in the mail the disclosures required under §1026.19(e)(1)(e)(1)(i) (provision of loan estimate form) not later than the seventh business day before consummation of the transaction

c. Written List of Service Providers (SSPL) Disclosure Date Test (12 CFR §1026.19(e)(1)(vi))

i. If the consumer is permitted to shop for a settlement service, the creditor shall provide the consumer with a written list identifying available providers of that settlement service and stating that the consumer may choose a different provider for that service. The creditor must identify at least one available provider for each settlement service for which the consumer is permitted to shop. The creditor shall provide this written list of settlement service providers separately from the disclosures required by §1026.19(e)(1)(e)(1)(i) but in accordance with the timing requirements in §1026.19(e)(1)(e)(1)(iii)

d. Your Home Loan Toolkit (§1026.19)

i. Verify there is evidence that the disclosure was provided to the borrower

ii. Validate Your Home Loan Toolkit was delivered or placed in the mail not later than three (3) business days after receipt of application

e. Borrowers Intent to Proceed (§1026.19); (§1026.25)

i. Verify there is evidence in the file indicating the borrowers intent to proceed

ii. If the lender documents the borrowers intent to proceed on a standalone disclosure, validate the borrower signed and dated the disclosure

f. Revised Loan Estimate Delivery Date Test (prior to consummation) (12 CFR §1026.19(e)(4)(ii))

i. The creditor shall not provide a revised version of the disclosures required under §1026.19(e)(1)(i) on or after the date on which the creditor provides the disclosures required under §1026.19(f)(1)(i). The consumer must receive a revised version of the disclosures required under §1026.19(e)(1)(i) not later than four business days prior to consummation. If the revised version of the disclosures required

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§1026.19(e)(1)(i) is not provided to the consumer in person, the consumer is considered to have received such version three business days after the creditor delivers or places such version in the mail

g. Valid Change of Circumstances Test

i. The changed circumstance(s) form was provided and the reason for re-disclosure is:

a. Changed circumstance affecting settlement charges; or

b. Changed circumstance affecting eligibility; or

c. Revisions requested by the consumer; or

d. Expiration of initial loan estimate; or

e. Delayed settlement date on a construction loan for new construction transactions only; or

f. The date the rate was set was not provided and Interest rate dependent charges change once the interest rate is locked;" or

g. The reason for re-disclosure is "Decrease in charges affecting settlement or eligibility, a consumer-requested revision, or other non-tolerance-related re-disclosure;" or

h. The initial loan estimate was not delivered timely

h. Initial Closing Disclosure Delivery Date Test (12 CFR §1026.19(f)(1)(ii))

i. The creditor shall ensure that the consumer receives the disclosures required under paragraph §1026.19(f)(1)(i) no later than three business days before consummation

i. Revised Closing Disclosure Delivery Date Test (waiting period vs. no waiting period required) (12 CFR §1026.19(f)(2)(i) & (ii))

i. If the disclosures provided under §1026.19(f)(1)(i) become inaccurate before consummation, the creditor shall provide corrected disclosures reflecting any changed terms to the consumer so that the consumer receives the corrected disclosures at or before consummation

ii. If the consumer determines that the extension of credit is needed to meet a bona fide personal financial emergency, the consumer may modify or waive the three-business-day waiting period for the revised closing disclosure after receiving the disclosures

j. TRID Tolerance Testing - Charges That Cannot Increase Test (12 CFR §1026.19(e)(3)(i))

i. An estimated closing cost disclosed pursuant to §1026.19(e) is in good faith if the charge paid by or imposed on the consumer does not exceed the amount originally disclosed under §1026.19(e)(1)(i)

k. TRID Tolerance Testing - Charges That in Total Cannot Increase More Than 10% Test (12 CFR §1026.19(e)(3)(ii))

i. The aggregate amount of charges for third-party services and recording fees paid by or imposed on the consumer does not exceed the aggregate amount of such charges disclosed under §1026.19(e)(1)(i) by more than 10 percent

l. TRID Tolerance Testing - Lender Credits That Cannot Decrease Test (12 CFR §1026.19(e)(3)(i))

i. An estimated closing cost disclosed pursuant to §1026.19(e) is in good faith if the charge paid by or imposed on the consumer does not exceed the amount originally disclosed under §1026.19(e)(1)(i)

m. TRID Reimbursement Amount Test (12 CFR §1026.19(f)(2)(v))

i. Refunds related to the good faith analysis. If amounts paid by the consumer exceed the amounts specified under §1026.19(e)(3)(i) or (ii), the creditor complies with §1026.19(e)(1)(i) if the creditor refunds the excess to the consumer no later than 60 days after consummation

n. TRID Reimbursement Date Test (12 CFR §1026.19(f)(2)(v))

i. Refunds related to the good faith analysis. If amounts paid by the consumer exceed the amounts specified under §1026.19(e)(3)(i) or (ii), the creditor complies with §1026.19(e)(1)(i) if the creditor refunds the excess to the consumer no later than 60 days after consummation

o. Disclosure of Escrow Account (§1026.38(l)(7)

i. If the loan indicates an escrow account will be established

a. Verify all amounts disclosed in the Projected Payments Table are accurate (§1026.38)(c); (§1026.37(c)

b. Verify all amounts disclosed in the Estimated Taxes, Insurance and Assessments (ETIA) are accurate (§1026.37(c)(4),(5)

c. Verify all amounts disclosed in Section G – Initial Escrow Payment and Closing are accurate (§1026.37(g)(3)

d. Verify all amounts disclosed in the Escrow Account Section are accurate (§1026.38(l)(7)

ii.  If the loan indicates an escrow account will not be established

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a. Verify all amounts disclosed in the Projected Payments Table are accurate (§1026.38(c); (§1026.37(c)

b. Verify all amounts disclosed in the Estimated Taxes, Insurance and Assessments (ETIA) are accurate (§1026.37(c)(4), (5)

c. Verify all amounts disclosed in the Escrow Account Section are accurate (§1026.38(l)(7)

p. Disclosure of Seller Paid Closing Costs (§1026.38(t)(5)(v)(B)

i. In transactions involving a seller, validate whether the lender disclosed all costs being paid by the seller on the borrowers Closing Disclosure

ii. If seller paid fees are present on the borrower’s Closing Disclosure, review the seller’s Closing Disclosure or alternative documentation for accuracy of disclosure

q. Post-consummation Event and Revised Closing Disclosure Delivery Date Test

i. The post-consummation revised closing disclosure delivery date is not more than 60 calendar days after the consummation date, or closing / settlement date if no consummation date was provided; and

ii. The provided reimbursement date is not more than 60 calendar days after the consummation date, or closing / settlement date if no consummation date was provided

r. Non-numeric Clerical Error and Post-consummation Revised Closing Disclosure Delivery Date Test (12 CFR §1026.19(f)(2)(iv))

i. A creditor does not violate §1026.19(f)(1)(i) if the disclosures provided under §1026.19(f)(1)(i) contain non-numeric clerical errors, provided the creditor delivers or places in the mail corrected disclosures no later than 60 days after consummation

s. Loan Calculation Test on the Closing Disclosure (12 CFR §1026.38)

i. Finance Charge

ii. Amount Financed

iii. Total of Payments

iv. Total Interest Percentage

4. Qualified Mortgage / Ability To Repay – Dodd Frank, as applicable

a. Classification of QM designated loan, if applicable

i. Validate whether the mortgage loan is a Safe Harbor QM or Higher Priced QM by comparing the mortgage loan’s actual annual percentage rate, as recalculated, to the applicable average prime offer rate plus a certain applicable percentage

ii. Determination of conformity thresholds (Safe Harbor or Rebuttable Presumption)

b. Negative Amortization Loan (12 CFR 1026.43(e)(2)(i)(A))

i. A qualified mortgage is a covered transaction that provides for regular periodic payments that are substantially equal, except for the effect that any interest rate change after consummation has on the payment in the case of an adjustable-rate or step-rate mortgage, that does not result in an increase of the principal balance

c. Interest Only Loan (12 CFR 1026.43(e)(2)(i)(B))

i. A qualified mortgage is a covered transaction that provides for regular periodic payments that are substantially equal, except for the effect that any interest rate change after consummation has on the payment in the case of an adjustable-rate or step-rate mortgage, that does not allow the consumer to defer repayment of principal

d. Balloon Payment Loan (12 CFR 1026.43(e)(2)(i)(C))

i. A qualified mortgage is a covered transaction that provides for regular periodic payments that are substantially equal, except for the effect that any interest rate change after consummation has on the payment in the case of an adjustable-rate or step-rate mortgage, that does not result in a balloon payment

e. Loan Term (12 CFR 1026.43(e)(2)(iii))

i. A qualified mortgage is a covered transaction for which the loan term does not exceed 30 years

f. Points and Fees (12 CFR §1026.43(e)(3))

i. Points and fees do not exceed the qualified mortgage points and fees threshold

g. DTI (12 CFR §1026.43(e)(2)(vi))

i. The ratio of the consumer's total monthly debt to total monthly income at the time of consummation does not exceed 43 percent, calculated in accordance with Appendix Q

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h. Prepayment Penalty (12 CFR 1026.43(g))

i. A covered transaction must not include a prepayment penalty unless:

a. The prepayment penalty is otherwise permitted by law; and the transaction:

b. Has an annual percentage rate that cannot increase after consummation;

c. Is a qualified mortgage under paragraph (e)(2), (e)(4), or (f) of this section; and

d. Is not a Higher Priced Mortgage Loan, as defined in § 1026.35(a)

5. Home Ownership and Equity Protection Act – HOEPA (Sections 32)

a. Federal HOEPA coverage (12 CFR §1026.32(a)(1)(i), (ii)

i. Tests that the loan is/is not secured by the consumer's principal dwelling; or

ii. Tests that the loan is/ is not an open-end credit plan; or

iii. That the application date of the loan occurs before/ after the effective date of October 1, 1995; or

iv. That the date the creditor received application occurs on or after January 10, 2014, the effective date of the High-Cost Mortgage amendments

b. High-Cost Mortgage APR threshold test (12 CFR §1026.32(a)(1)(i)(A), (C))

i. The loan is secured by a first-lien transaction, and the annual percentage rate (APR) does not exceed the Average Prime Offer Rate by more than 6.5%; or

ii. The loan is a subordinate-lien transaction, and the annual percentage rate (APR), does not exceed the Average Prime Offer Rate by more than 8.5%

c. High-Cost Mortgage Points and Fees Threshold Test (12 CFR §1026.32(a)(1)(ii)(A), (B))

i. The total points and fees does not exceed allowable limits per the given loan amount

d. High-Cost Mortgage Prepayment Penalty Threshold Test (12 CFR §1026.32(a)(1)(iii))

i. The loan contract or open-end credit agreement does not allow the creditor to charge:

a. A prepayment penalty more than 36 months after consummation or account opening; or

b. Prepayment penalties that can exceed, in total, more than 2 percent of the amount prepaid

e. High-Cost Mortgage (12 CFR §1026.32(a)(1))

f. High-Cost Mortgage Repayment Ability Test (12 CFR §1026.34(a)(4), 1026.43)

g. Other high-costs tests pursuant to (12 CFR §1026.32(a)(1))

i. Timing of disclosures

ii. Balloon payment

iii. Negative amortization

iv. Prepayment penalty

v. Pre-loan counseling

vi. Late charges

vii. Grace period

viii. Financing of points and fees

6. Higher Priced Mortgage Loan – HMPL (section 35)

a. Higher Priced Mortgage Loan test (12 CFR §1026.35(a)(1))

b. Higher Priced Mortgage Loan required escrow account test (12 CFR §1026.35(a)(1), (b)(2)(i)(A))

c. Higher Priced Mortgage Loan prepayment term test

d. Higher Priced Mortgage Loan escrow account test (12 CFR §1026.35(a))

7. Prohibited Acts – Brokers Comp

a. Broker Compensation Test (12 CFR §1026.36(d)(2)

i. If any loan originator receives compensation directly from a consumer in a consumer credit transaction secured by a dwelling:

a. No loan originator shall receive compensation, directly or indirectly, from any person other than the consumer in connection with the transaction; and

b. No person who knows or has reason to know of the consumer-paid compensation to the loan originator (other than the consumer) shall pay any compensation to a loan originator, directly or indirectly, in connection with the transaction

8. Nationwide Mortgage Licensing System (NMLS) Tests (12 CFR §1026.36)

a. review for presence of mortgage loan originator organization and individual mortgage loan originator name and NMLSR ID, as applicable, on the credit application, note or mortgage loan contract, security instrument, Loan Estimate and Closing Disclosure; and

b. verify the data against the NMLSR database, as available

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B. Real Estate Settlement Procedures Act – 12 CFR §1024 (“RESPA”)

1. Federal RESPA

a. Homeownership Counseling Organizations Disclosure Date Test (12 CFR §1024.20(a))

i. Not later than three business days after a lender, mortgage broker, or dealer receives an application, or information sufficient to complete an application, the lender must provide the loan applicant with a clear and conspicuous written list of homeownership counseling organizations that provide relevant counseling services in the loan applicant's location

ii. The list of homeownership counseling organizations distributed to each loan applicant under this section shall be obtained no earlier than 30 days prior to the time when the list is provided to the loan applicant

a. Good Faith Estimate Disclosure Test (12 CFR §1024.7)

i. Not later than 3 business days after a loan originator (broker or lender) receives an application for a federally related mortgage loan, or information sufficient to complete an application, the loan originator must provide the applicant with a GFE

b. Good Faith Estimate Disallowed Credit and Charge test (GFE Block 2)

i. Looks for any amounts entered for both a loan discount fee and a yield spread premium or a lender credit

ii. Only one charge or one credit affecting the interest rate is allowed under the new RESPA regulations

C. Equal Credit Opportunity Act – 12 CFR §1002 (“ECOA”)

1. ECOA Valuation Rule (12 CFR §1002.14(a)(1))

a. Review all applicable loans for the Disclosure of Right to Receive a Copy of Appraisals. Validate if the customer(s) waived their right to receive copies of their appraisals three business days prior to consummation/account opening

b. Review all applicable loans for proof that lender delivered copies of appraisals and other written valuations three business days before consummation (closed-end), or account opening (open-end)

c. If the customer(s) waived their right to receive copies of their appraisals three business days prior to consummation/account opening, review the Post-Closing submission for an Acknowledgment of Receipt of Appraisal Report, or other proof that the lender provided provide the copies either at, or prior to, consummation or account opening

d. State Specific tests (varies by state and applicability, by at a minimum includes);

i. Consumer / Home Loan tests

ii. High cost tests

iii. Higher Priced Mortgage Loan tests

iv. APR threshold tests

v. Points and fees threshold tests

vi. Cover loan tests

vii. Negative Amortization tests

viii. Prepayment tests

Document Review

EdgeMAC reviewed all mortgage loan files supplied and verified that the following documents, if applicable, were included in the file and that the data on the documents was consistent:

· Initial Application (1003)

· Final Application (1003)

· Loan Approval (1008)

· HUD1 from Sale of Previous Residence

· Loan Estimates and Closing Disclosures

· Sales Contract

· Mortgage/Deed of Trust

· Note

· Guaranty Agreement

· Occupancy Affidavit

· Lease Agreements

Page 9 of 14

· Business Purpose Affidavit

· Junior Lien Information

· Subordination Agreement

· Income Documentation

· Employment Documentation

· Asset Documentation

· Credit Reports

· 4506T/Tax Documentation

· Change of Circumstance Documentation

· Disclosures: Right of Rescission, Net Tangible Benefit and FACTA

· Appraisal Valuation Reports

· Title/Preliminary Title

· Flood and Hazard Insurance Policies

· Flood Certificates

Summary of findings and conclusions of review

Below provides the summary of the review findings:

Final Overall Grade Summary

Overall	# of Mortgage Loans	% of Mortgage Loans
A	11	8.40%
B	120	91.60%
Total	131	100.00%

Credit Grade Summary

Credit	# of Mortgage Loans	% of Mortgage Loans
A	78	59.54%
B	53	40.46%
Total	131	100.00%

Compliance Grade Summary

Compliance	# of Mortgage Loans	% of Mortgage Loans
A	21	16.03%
B	110	83.97%
Total	131	100.00%

Property Grade Summary

Property	# of Mortgage Loans	% of Mortgage Loans
A	131	100.00%
Total	131	100.00%

Page 10 of 14

Exception Summary

Below provides a summary of the individual exceptions based on the general categories of Credit, Compliance, and Property.

Credit Exception Categories	Exception Count	Exception Grade C	Exception Grade B
Credit - General Underwriting Guideline Violation	64	0	64
Credit - Income and Assets	10	0	10
Credit - Credit	4	0	4
Total	78		78

Compliance Exception Categories	Exception Count	Exception Grade C	Exception Grade B
Compliance - Regulatory Compliance	205	0	205
Total	205		205

Property Exception Categories	Exception Count	Exception Grade C	Exception Grade B
None
Total

Data Integrity Summary

The table below provides a summary of the data compare results:

Field Name	# of Discrepancies	% Accuracy
Amortization Term	3	97.69%
Appraisal Value	9	93.08%
Borrower First Name	0	100.00%
Borrower Last Name	0	100.00%
Borrower Self-Employed	2	98.44%
Borrower SSN	0	100.00%
Co Borrower 1 Self-Employed	1	96.30%
Co-Borrower 1 SSN	0	100.00%
Coborrower 1 First Name	0	100.00%
Coborrower 1 Last Name	0	100.00%
Doc Type	0	100.00%
First Payment Date	0	100.00%
First Rate Adjustment Date	0	100.00%
FTHB Flag	0	100.00%
Initial Rate Adjustment Period	0	100.00%
Interest Only Flag	0	100.00%

Page 11 of 14

Interest Only Months	0	100.00%
Interest Rate Initial Cap	0	100.00%
Interest Rate Life Cap	0	100.00%
Interest Rate Life Ceiling	0	100.00%
Interest Rate Periodic Cap	0	100.00%
Interest Rate Rate Change Frequency	0	100.00%
Interset Rate Life Floor	0	100.00%
Investor Qualifying DSCR	0	100.00%
Investor Qualifying DTI	104	19.38%
Lien Position	0	100.00%
Loan Purpose	0	100.00%
Loan Type	0	100.00%
Margin	1	99.23%
Maturity Date	0	100.00%
MERS Min Number	0	100.00%
Note Date	0	100.00%
Number of Units	0	100.00%
Occupancy Type	0	100.00%
Original CLTV	1	99.22%
Original Interest Rate	0	100.00%
Original Loan Amount	0	100.00%
Original LTV	1	99.22%
Original P&I	0	100.00%
Original Term	0	100.00%
Prepayment Flag	0	100.00%
Prepayment Term	0	100.00%
Property City	0	100.00%
Property State	0	100.00%
Property Street Address	0	100.00%
Property Type	6	95.35%
Property Zip	1	99.23%
QM Designation	0	100.00%
Qualifying Credit Score	4	96.92%
Sales Price	0	100.00%
Total	118	96.73%

General Loan Population Summary

Property State	Loan Count	% of Loans	Original Balance	% of Balance
AZ	5	3.82%	$1,824,250.00	4.45%
CA	9	6.87%	$3,838,665.00	9.36%

Page 12 of 14

CO	2	1.53%	$580,200.00	1.41%
CT	3	2.29%	$854,900.00	2.08%
DE	1	.76%	$295,800.00	.72%
FL	47	35.88%	$16,086,358.00	39.21%
GA	3	2.29%	$494,600.00	1.21%
HI	2	1.53%	$1,043,500.00	2.54%
ID	1	.76%	$389,000.00	.95%
IL	9	6.87%	$1,951,705.00	4.76%
IN	3	2.29%	$622,100.00	1.52%
LA	2	1.53%	$666,900.00	1.63%
MD	3	2.29%	$620,200.00	1.51%
MI	3	2.29%	$1,296,310.00	3.16%
MO	1	.76%	$76,000.00	.19%
NC	4	3.05%	$1,093,090.00	2.66%
NJ	8	6.11%	$2,493,600.00	6.08%
NV	1	.76%	$141,000.00	.34%
NY	1	.76%	$663,200.00	1.62%
OK	1	.76%	$408,600.00	1.00%
OR	1	.76%	$448,375.00	1.09%
PA	6	4.58%	$1,956,390.00	4.77%
RI	1	.76%	$140,000.00	.34%
TN	1	.76%	$204,000.00	.50%
TX	12	9.16%	$2,770,441.00	6.75%
WI	1	.76%	$71,250.00	.17%
Total	131	100.00%	$41,030,434.00	100.00%

Amortization Type	Loan Count	% of Loans	Original Balance	% of Balance
Adjustable	74	56.49%	$26,385,680.00	64.31%
Fixed	57	43.51%	$14,644,754.00	35.69%
Total	131	100.00%	$41,030,434.00	100.00%

Lien Position	Loan Count	% of Loans	Original Balance	% of Balance
1	131	100.00%	$41,030,434.00	100.00%
Total	131	100.00%	$41,030,434.00	100.00%

Loan Purpose	Loan Count	% of Loans	Original Balance	% of Balance
Purchase	105	80.15%	$28,904,234.00	70.45%
Refinance - cash out	20	15.27%	$9,887,150.00	24.10%
Refinance - rate and term	6	4.58%	$2,239,050.00	5.46%
Total	131	100.00%	$41,030,434.00	100.00%

Page 13 of 14

Original Term	Loan Count	% of Loans	Original Balance	% of Balance
360	129	98.47%	$40,748,034.00	99.31%
480	2	1.53%	$282,400.00	.69%
Total	131	100.00%	$41,030,434.00	100.00%

Originator Loan Designation	Loan Count	% of Loans	Original Balance	% of Balance
Non-Qualified Mortgage	121	92.37%	$39,255,284.00	95.67%
Not covered / exempt	10	7.63%	$1,775,150.00	4.33%
Total	131	100.00%	$41,030,434.00	100.00%

Property Type	Loan Count	% of Loans	Original Balance	% of Balance
2-4 Family	4	3.05%	$1,288,500.00	3.14%
High Rise Condo (8+ Stories)	4	3.05%	$753,000.00	1.84%
Low Rise Condo (1-4 stories)	19	14.50%	$3,847,009.00	9.38%
PUD (Planned Unit Development)	46	35.11%	$15,168,650.00	36.97%
Single Family Detached	58	44.27%	$19,973,275.00	48.68%
Total	131	100.00%	$41,030,434.00	100.00%

Occupancy Type	Loan Count	% of Loans	Original Balance	% of Balance
Investment Property	10	7.63%	$1,775,150.00	4.33%
Primary Residence	112	85.50%	$37,018,934.00	90.22%
Second Home	9	6.87%	$2,236,350.00	5.45%
Total	131	100.00%	$41,030,434.00	100.00%

Page 14 of 14

EX-99.1

Exhibit 99.1 - Schedule 1

TPR Firm:	EdgeMAC	Date Submitted:	10/30/2019
Client Name:	Sprout	Report:	Exception Report
Client Project:	HOF 2019-3	Loans in report:	131

Report Date

Loan Number

Edge MAC ID

Seller Loan Number

Originator

General Category

Exception

Exception ID

Date Exception Cured Waived Updated

Description of Clearance

Comments

Compensating Factors

Exception Status

Exception Category

Exception Event Level

Initial Review Date

Occupancy Type

Property State

Note Date

Loan Purpose

TILA Rating

Loan Initial

Loan Final

Credit Initial

Credit Final

Compliance Initial

Compliance Final

Property Initial

Property Final

10/30/2019

430537539

XXXX

XXXX

XXXX

Credit - Credit

Client approved exception to not require 12 month verification of rental payment history vs program requirement of a 12 month verification of rental payment history must be obtained. Compensating Factors 1. 666 Fico score is 26 point greater than minimum 640 required by the guidelines2. LTV of 81.374% is 3.626% lower than the maximum of 85% allowed by the guidelines 3. DTI of 44.47%, 5.53% lower than the max DTI of 50.00% as required in the guidelines4. No public records

7000-2605

8/14/2019

Waived/Exception Granted

Compensating Factors 1. 666 Fico score is 26 point greater than minimum 640 required by the guidelines 2. LTV of 81.374% is 3.626% lower than the maximum of 85% allowed by the guidelines 3. DTI of 44.47%, 5.53% lower than the max DTI of 50.00% as required in the guidelines 4. No public records

Waived

Credit

EG2

8/14/2019

Primary Residence

NY

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537539

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Escrowed Property Costs over Year 1 of $16,007.31 on the 05/21/2019 final Closing Disclosure does not correspond with the stated ETIA Monthly Escrow Payment of $1,260.41 as listed on page 1 and page 4. The figure disclosed in the Escrowed Property Costs over Year 1 field on page 4 should be exactly divisible by the Monthly Escrow Payment by 10, 11, or 12 months. Need Post Consummation Closing Disclosure with borrower letter and proof of mailing of all documents, reflecting the corrected Escrowed Property Costs over Year 1 figure.

7000-2607

8/14/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/14/2019: Received PCCD with borrower letter and proof of delivery, reflecting corrected Escrowed Property Cost over Year 1 figure.

Compensating Factors 1. 666 Fico score is 26 point greater than minimum 640 required by the guidelines 2. LTV of 81.374% is 3.626% lower than the maximum of 85% allowed by the guidelines 3. DTI of 44.47%, 5.53% lower than the max DTI of 50.00% as required in the guidelines 4. No public records

Cured

Compliance

EG2

8/14/2019

Primary Residence

NY

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537539

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 08/15/2019: Received stand-alone copy of legal description that corresponds with title commitment and Mortgage. However, it is unknown if the aforementioned legal description recorded with the xx/xx/xx Bargain and Sale Deed with Covenant Against Grantor (Individual). Please provide either recorded copy of the Bargain and Sale Deed with Covenant Against Grantor (Individual) reflecting the legal description per the title commitment/Mortgage or provide final title policy, reflecting subject lien. //UPDATE 08/14/2019: Received xx/xx/xx Bargain and Sale Deed with Covenant Against Grantor (Individual) which was the same document that was in file with the legal description that doesn't match the Mortgage. Document not properly executed or dated:  The legal description attached to the Bargain and Sale Deed with Covenant Against Grantor dated xx/xx/xx does not match the legal description attached to the title commitment nor the subject Mortgage. Also, the lot number referenced on the subject Mortgage (xx) on page 1 doesn't match the lot number referenced in the legal description (xx); there was no Closing Protection Letter nor executed Closing Instructions found in file.

7000-2608

8/16/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

received lender's attestation that Deed is being re-recorded

Compensating Factors 1. 666 Fico score is 26 point greater than minimum 640 required by the guidelines 2. LTV of 81.374% is 3.626% lower than the maximum of 85% allowed by the guidelines 3. DTI of 44.47%, 5.53% lower than the max DTI of 50.00% as required in the guidelines 4. No public records

Cured

Compliance

EG2

8/14/2019

Primary Residence

NY

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537539

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 08/14/2019: Final Seller CD in file which reflects all seller-paid fees. Changed  to EG2 for Client to either address or choose to waive. The loan contains errors within one or more TRID disclosure. The Closing Disclosure XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2599

8/15/2019

Waived/Exception Granted

Compensating Factors 1. 666 Fico score is 26 point greater than minimum 640 required by the guidelines 2. LTV of 81.374% is 3.626% lower than the maximum of 85% allowed by the guidelines 3. DTI of 44.47%, 5.53% lower than the max DTI of 50.00% as required in the guidelines 4. No public records

Waived

Compliance

EG2

8/14/2019

Primary Residence

NY

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537539

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  NY Lock-In Agreement and NY Notice of Expiration of Lock-in Agreement/Lock Commitment.

7000-2601

8/14/2019

Waived/Exception Granted

Compensating Factors 1. 666 Fico score is 26 point greater than minimum 640 required by the guidelines 2. LTV of 81.374% is 3.626% lower than the maximum of 85% allowed by the guidelines 3. DTI of 44.47%, 5.53% lower than the max DTI of 50.00% as required in the guidelines 4. No public records

Waived

Compliance

EG2

8/14/2019

Primary Residence

NY

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537539

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing appraisal invoice to confirm Appraisal Fee of $495.00 and $595.00 as reflected on Final Closing Disclosure dated XXXX.

7000-2602

8/15/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/15/2019: Received appraisal invoices which reconcile with the PCCD.

Compensating Factors 1. 666 Fico score is 26 point greater than minimum 640 required by the guidelines 2. LTV of 81.374% is 3.626% lower than the maximum of 85% allowed by the guidelines 3. DTI of 44.47%, 5.53% lower than the max DTI of 50.00% as required in the guidelines 4. No public records

Cured

Compliance

EG1

8/14/2019

Primary Residence

NY

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537540

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Exception approved for LTV at 90.00%. Program max 85% due to loan amount of $x,xxx,xxx.

7000-74

11/21/2018

Waived/Exception Granted

Client Elected to Waive condition with compensating factors.

Compensating Factors: 1. DTI of 27.61%, 10.39% under guidelines maximum DTI of 38% 2. Residual Income of $36,926.28

Waived

Credit

EG2

11/21/2018

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537540

XXXX

XXXX

XXXX

Credit - Credit

Missing credit report used to qualify borrower. Copy in file is a soft pull dated xx/xx/xx, does not reflect credit scores.

7000-76

2/8/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Note- 1008 reflects qualifying FICO of 712 - Do not have this CBR

Compensating Factors: 1. DTI of 27.61%, 10.39% under guidelines maximum DTI of 38% 2. Residual Income of $36,926.28

Cured

Credit

EG1

11/21/2018

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537540

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Electronic Consent/ eSign Form

7000-79

1/28/2019

Waived/Exception Granted

Compensating Factors: 1. DTI of 27.61%, 10.39% under guidelines maximum DTI of 38% 2. Residual Income of $36,926.28

Waived

Compliance

EG2

11/21/2018

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537540

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  CA Hazard Insurance Disclosure

7000-80

1/28/2019

Waived/Exception Granted

Compensating Factors: 1. DTI of 27.61%, 10.39% under guidelines maximum DTI of 38% 2. Residual Income of $36,926.28

Waived

Compliance

EG2

11/21/2018

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537540

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Adjustable Rate Mortgage Disclosure (ARM) is in file, however, it is dated xx/xx/xx which is more than 3 business days from XXXX, date in which file was locked as an ARM loan. Need proof ARM disclosure was issued within 3 business days of application.

7000-82

1/28/2019

Waived/Exception Granted

Compensating Factors: 1. DTI of 27.61%, 10.39% under guidelines maximum DTI of 38% 2. Residual Income of $36,926.28

Waived

Compliance

EG2

11/21/2018

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537540

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 02/22/2019: Revised PC CD, borrower letter, and proof of mailing was provided. However, the documentation did not include a reimbursement check for finance charge under disclosure as it was understated by more than $100.00 The total under disclosed amount was -$212.50. Also, the borrower letter needs to specify that it was as a result of a finance charge under disclosure, and a new proof of mailing needs to be provided.  This loan failed the TILA finance charge test.(12 CFR 1026.18(d)(1), transferred from 12 CFR 226.18(d)(1))The finance charge is $x,xxx,xxx,xx. The disclosed finance charge of $x,xxx,xxx,xx is not considered accurate because it is understated by more than $100.00.   The total under disclosed amount $-212.50.

7000-84

2/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE: 02/25/2019; Appraisal fee is excluded from finance charge calculation as long as it is bona fide and reasonable. Removed from CE testing and loan now passes. No cure needed //UPDATE 02/22/2019: Revised PC CD, borrower letter, and proof of mailing was provided. However, the documentation did not include a reimbursement check for finance charge under disclosure as it was understated by more than $100.00 The total under disclosed amount was -$212.50. Also, the borrower letter needs to specify that it was as a result of a finance charge under disclosure, and a new proof of mailing needs to be provided.

Compensating Factors: 1. DTI of 27.61%, 10.39% under guidelines maximum DTI of 38% 2. Residual Income of $36,926.28

Cured

Compliance

EG1

11/21/2018

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537540

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. Closing Disclosure in file dated XXXX reflects Title fees in section C payable to a service provider listed on the Written List of Providers.  Need Post Consummation Closing Disclosure reflecting fees in section B along with explanation letter to borrower and proof of method of delivery of all to borrower.

7000-87

1/28/2019

Waived/Exception Granted

Compensating Factors: 1. DTI of 27.61%, 10.39% under guidelines maximum DTI of 38% 2. Residual Income of $36,926.28

Waived

Compliance

EG2

11/21/2018

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537540

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing proof that creditor delivered copy of 2nd appraisal either at, or prior to, consummation. ECOA Valuations Rule violation (1002.14(a)(1)).

7000-89

6/14/2019

Waived/Exception Granted

Compensating Factors: 1. DTI of 27.61%, 10.39% under guidelines maximum DTI of 38% 2. Residual Income of $36,926.28

Waived

Compliance

EG2

11/21/2018

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller exception due to LTV is 80.335% vs program maximum of 80%.Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed2. Residual Income = $109,107.203. Self Employed for +17 Years in line of business

7000-586

2/19/2019

Waived/Exception Granted

The client elected to waive this exception

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Waived

Credit

EG2

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

EdgeMAC does not consider negative per diem interest as a credit against the total finance charge.  Please provide a PCCD with letter of explanation and proof of method of delivery to the borrower that discloses the prepaid interest amount in line F03 as $0.00 and use an offsetting lender credit in section H with a description of applicability to underdisclosed finance charges to properly apply the credit and accurately disclose the credit to finance charges.TILA Post-Consummation Revised Closing Disclosure Lending PoliciesThis loan failed the TILA finance charge test.(12 CFR 1026.18(d)(1), transferred from 12 CFR 226.18(d)(1))The finance charge is $xxx,xxx.xx. The disclosed finance charge of $xxx,xxx.xx is not considered accurate because it is understated by more than $100.00.  The total under disclosed amount is -$1,364.88.

7000-398

1/23/2019

Waived/Exception Granted

The client elected to waive this exception

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Waived

Compliance

EG2

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

// UPDATE 01/28/2019: While the TRID Rule states that a lender should include negative interest when calculating the Total Interest Payment (TIP) under 12 CFR 1026  37(g)(2) and 38(g)(2), the Bureau notably did not make any similar revisions to 12 CFR  1026.38(o)(1), or the corresponding commentary, regarding calculation of the TOP, however EdgeMAC will allow for lender's to included the negative pre paid interest in their calculation.//UPDATE 01/23/2019: As requested, the TOP calculation, based on the XXXX PC CD, is the sum of:  Principal:  $xxx,xxx.00Interest:  $xxx,xxx.28Mortgage Insurance:  $0.00Loan Costs:  $2,446.00TOTAL OF PAYMENTS (TOP):  $x,xxx,xxx.xx   TOP Disclosed on XXXX PC CD (pg. 5): $x,xxx,xxx.xxUnder-disclosed Amount: $x,xxx,xxx.xx - $x,xxx,xxx.xx = -$1,109.88The loan contains errors within one or more TRID disclosure.Total of Payments ThresholdsThis loan failed the TRID total of payments test. (12 CFR 1026.18(d)(1))The total of payments is $x,xxx,xxx.xx. The disclosed total of payments of $x,xxx,xxx.xx is not considered accurate because it is understated by more than $100.00.  The total under disclosed amount is -$1,109.88.

7000-399

1/28/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 01/23/2019: As requsted, the TOP calculation, based on the xx/xx/xxxx PC CD, is the sum of:   Principal:  $xxxx Interest:  $xxxx Mortgage Insurance:  $0.00 Loan Costs:  $2,446.00 TOTAL OF PAYMENTS (TOP):  $xxxx    TOP Disclosed on 10/09/2018 PC CD (pg. 5): $xxxx Under-disclosed Amount: $xxxx - $xxxx = -$1,109.88

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Cured

Compliance

EG1

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  Missing proof of method of delivery for Post Consummation CD in file dated XXXX.

7000-400

1/23/2019

Waived/Exception Granted

The client elected to waive this exception

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Waived

Compliance

EG2

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure, NJ Loan Commitment, and NJ Mortgage Broker Agreement.

7000-401

1/23/2019

Waived/Exception Granted

The client elected to waive this exception

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Waived

Compliance

EG2

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Notice of Special Flood Hazard disclosure is in file, however, it is not signed.  Need signed Notice of Special Flood Hazard disclosure.

7000-402

1/23/2019

Waived/Exception Granted

The client elected to waive this exception

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Waived

Compliance

EG2

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Post Consummation Closing Disclosure in file dated XXXX contains inaccurate ETIA information on page 1 and Escrow Account information on page 4.  ETIA amount on page 1 should reflect $x,xxx,xxx.xx total, reflecting Insurance monthly amount of $165.03, Property Tax monthly amount of $1,104.60, Flood Insurance monthly amount of $213.33 and Non-Escrowed HOA Dues of $16.67 monthly.  Escrowed Property Costs over Year 1 on page 4 would then be $17,795.52 and Monthly Escrow Payment would be $1,482.96.

7000-403

1/23/2019

Waived/Exception Granted

The client elected to waive this exception

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Waived

Compliance

EG2

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Credit - Credit

Missing Verification of Rent for borrower's residence at XXXX. Include lease term with month/year start and termination, if applicable./////1/23/2019/////Insufficient to clear - Missing pay history from April 2018 to July 2018.

7000-407

1/28/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

1/28/19 1X30X12

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Cured

Credit

EG1

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing copy of appraisal completed on xx/xx/xx with $XXXK value. As referenced on seller Exception form. LTV is subject to recalculation.

7000-425

1/28/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Cured

Credit

EG1

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing copy of Second Home Rider.

7000-426

2/19/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

2/19

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Cured

Credit

EG1

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing copy of signed conditional loan approval at the time of origination.

7000-427

1/28/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

1/28

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Cured

Credit

EG1

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing copy of homeowner's insurance with correct mailing address.

7000-428

1/23/2019

Property condition cleared

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Cured

Credit

EG1

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537541

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On CD issued XXX, under the Estimated Taxes, Insurance and Assessments section on page one, This estimate includes, Other is missing a description of the other assessments that are not in escrow.  Need Post Consummation CD with a description of the other assessments that are not in escrow and explanation letter to borrower with proof of method of delivery of all to borrower.

7000-382

1/23/2019

Waived/Exception Granted

Compensating Factors: 1. DTI < 23.772% Less than max of 43% allowed 2. Residual Income = $109,107.20 3. Self Employed for +17 Years in line of business

Waived

Compliance

EG2

1/21/2019

Second Home

NJ

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537543

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID timing of disclosures.  Missing revised Loan Estimate that reflects XXXX rate lock details.

7000-2752

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/22/2019 Received re-disclosed LE dated xx/xx/xxxx reflecting loan as locked.

Compensating Factors: 1. 9.837% DTI, 33.163% less than program guideline maximum DTI of 43.00% 2. 749 FICO scores, 69 points greater than program guideline minimum FICO of 680 3. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 5 years

Cured

Compliance

EG1

8/21/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537543

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE:  08/22/2019 Received a PC CD dated XXXX attached to this condition, however, this CD is STILL MISSING All Seller Paid Fees according to the XXXX Settlement Statement in file.  STILL NEED Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD or Client may choose to waive.The loan contains errors within one or more TRID disclosure.  The Closing Disclosure (CD) in file dated XXXX is missing all of the Seller Paid fees according to the XXXX Settlement Statement in file dated XXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-2737

8/22/2019

Waived/Exception Granted

Compensating Factors: 1. 9.837% DTI, 33.163% less than program guideline maximum DTI of 43.00% 2. 749 FICO scores, 69 points greater than program guideline minimum FICO of 680 3. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 5 years

Waived

Compliance

EG2

8/21/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537543

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID timing of disclosures.  Missing Written List of Service Providers with proof issued within 3 business days of application date.  Unable to complete regulatory compliance check and TRID Monitoring.

7000-2738

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/22/2019 Received Services You Can Shop For dated xx/xx/xxxx

Compensating Factors: 1. 9.837% DTI, 33.163% less than program guideline maximum DTI of 43.00% 2. 749 FICO scores, 69 points greater than program guideline minimum FICO of 680 3. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 5 years

Cured

Compliance

EG1

8/21/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537543

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID timing of disclosures.  According to the Uniform Residential Loan Application (1003) in file, the application date is XXXX, and the initial Loan Estimate (LE) is missing from the file.  Unable to complete regulatory compliance check and TRID monitoring.

7000-2740

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/22/2019 Received Initial LE dated xx/xx/xxxx

Compensating Factors: 1. 9.837% DTI, 33.163% less than program guideline maximum DTI of 43.00% 2. 749 FICO scores, 69 points greater than program guideline minimum FICO of 680 3. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 5 years

Cured

Compliance

EG1

8/21/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537543

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID timing of disclosures.  Missing Initial Closing Disclosure (CD) with proof issued at least 3 days prior to consummation.  Closing Disclosure in file is signed at consummation on XXXX.  Unable to complete regulatory compliance check and TRID monitoring.

7000-2741

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/22/2019 Received Initial CD dated xx/xx/xxxx reflecting eSigned xx/xx/xxxx

Compensating Factors: 1. 9.837% DTI, 33.163% less than program guideline maximum DTI of 43.00% 2. 749 FICO scores, 69 points greater than program guideline minimum FICO of 680 3. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 5 years

Cured

Compliance

EG1

8/21/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537543

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Housing Counselors Near You, with proof issued within 3 business days of application date.

7000-2742

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/22/2019 Received Housing Counseling List dated xx/xx/xxxx

Compensating Factors: 1. 9.837% DTI, 33.163% less than program guideline maximum DTI of 43.00% 2. 749 FICO scores, 69 points greater than program guideline minimum FICO of 680 3. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 5 years

Cured

Compliance

EG1

8/21/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537543

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Privacy Policy and FL Anti-Coercion/Choice of Insurance Notice.

7000-2743

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/22/2019 Received Disclosure Tracking Details reflecting both Privacy Policy and FL Anti-Coercion Disclosure were issued to borrower xx/xx/xxxx

Compensating Factors: 1. 9.837% DTI, 33.163% less than program guideline maximum DTI of 43.00% 2. 749 FICO scores, 69 points greater than program guideline minimum FICO of 680 3. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 5 years

Cured

Compliance

EG1

8/21/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537543

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID timing of disclosures.  Missing "Your Home Loan Toolkit," and there is no cover letter that identifies the Toolkit was provided within 3 business days of application date.

7000-2744

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/22/2019 Received Disclosure Tracking Details reflecting Your Home Loan Toolkit was issued to borrower xx/xx/xxxx

Compensating Factors: 1. 9.837% DTI, 33.163% less than program guideline maximum DTI of 43.00% 2. 749 FICO scores, 69 points greater than program guideline minimum FICO of 680 3. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 5 years

Cured

Compliance

EG1

8/21/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537544

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.   Lender Credit was removed on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits($284.75).

7000-2496

8/16/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

Received PCCD with lender cure along with POD, copy of cure check and LOE

Compensating Factors: 1. 30.74% DTI, 19.26% less than program guideline maximum DTI of 50.00% 2. 755 FICO scores, 75 points greater than program guideline minimum FICO scores of 680 3. 14 months reserves, 11 months greater than program guideline 3 months reserves requirement 4. 85.00% LTV, 5% less than program guideline maximum LTV  of 90.00% 5. No public records

Cured

Compliance

EG2

8/7/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537545

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing Use of Funds letter from CPA regarding use of business assets in XXXX Business Checking account, account xxxxxx, and the impact, if any, it would have on the borrower's business. CPA letter in file only states the borrower buying a home would not affect the borrower's business or assets.

7000-2123

7/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

07/02/2019: CPA letter accepted by As Is by xxxx. Please see e-mail in QA folder.

Compensating Factors: 1. 33.00% DTI, 17.00% less than program guideline maximum DTI of 50.00% 2. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 10 years 4. 665 FICO, 5 points greater than program guideline minimum FICO of 660

Cured

Credit

EG1

6/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537545

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing source of Earnest Money Deposit in the amount of $xx,xxxx.xx.

7000-2125

7/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

7/1/19: Received copy of cancelled checks for EMDs.

Compensating Factors: 1. 33.00% DTI, 17.00% less than program guideline maximum DTI of 50.00% 2. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 10 years 4. 665 FICO, 5 points greater than program guideline minimum FICO of 660

Cured

Credit

EG1

6/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537545

XXXX

XXXX

XXXX

Credit - Income and Assets

ADDED 07/01/2019: Missing evidence funds used for earnest money deposits ($x,xxx on xx/xx/xx and $x,xxx on xx/xx/xx) were transferred from borrower's business account to personal account prior to escrow as required by guidelines.Compensating Factors:1. 33.00% DTI, 17.00% less than program guideline maximum DTI of 50.00%2. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement3. Owner of the same business for 10 years4. 665 FICO, 5 points greater than program guideline minimum FICO of 660

7000-2138

7/8/2019

Waived/Exception Granted

07/08/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 33.00% DTI, 17.00% less than program guideline maximum DTI of 50.00% 2. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 10 years 4. 665 FICO, 5 points greater than program guideline minimum FICO of 660

Waived

Credit

EG2

6/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537545

XXXX

XXXX

XXXX

Credit - Income and Assets

Client approved exception to allow funds for down payment coming from borrower's business account vs program requirement that if funds in a business bank or brokerage account have not been transferred to the Borrowers' personal accounts, such funds may not be included in Down Payment and Closing Funds.Compensating Factors:1. 33.00% DTI, 17.00% less than program guideline maximum DTI of 50.00%2. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement3. Owner of the same business for 10 years4. 665 FICO, 5 points greater than program guideline minimum FICO of 660

7000-2170

7/8/2019

Waived/Exception Granted

07/08/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 33.00% DTI, 17.00% less than program guideline maximum DTI of 50.00% 2. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 10 years 4. 665 FICO, 5 points greater than program guideline minimum FICO of 660

Waived

Credit

EG2

6/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537545

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-2082

6/28/2019

Waived/Exception Granted

Compensating Factors: 1. 33.00% DTI, 17.00% less than program guideline maximum DTI of 50.00% 2. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 10 years 4. 665 FICO, 5 points greater than program guideline minimum FICO of 660

Waived

Compliance

EG2

6/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Qualify borrower using annual base pay from WVOE for borrower who recently started new job on xx/xx/xx. VS program requirement to evidence a minimum 30 days earnings.Compensating Factors:1.643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2.DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines3.Borrower has been in same line of work for the last 25 years

7000-1883

6/10/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Credit

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Qualify borrower using potential bonus income of $x,xxx per month (30% of annual income) as per WVOE from new employer vs program requirement to qualify bonus income.Compensating Factors:1.643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2.DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines3.Borrower has been in same line of work for the last 25 years

7000-1884

6/10/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Credit

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Adjustable Rate Mortgage Disclosure (ARM) is in file, however, it is not dated and signed on XXXX which is outside the 3 day disclosure requirement.  Need proof issued within 3 business days of application.

7000-1890

6/12/2019

Waived/Exception Granted

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Compliance

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing appraisal invoice to confirm Appraisal Fee of $150.00 as reflected on Closing Disclosure dated XXXX.

7000-1891

6/12/2019

Waived/Exception Granted

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Compliance

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  e-Disclosure Consent/e-Sign Form completed prior to earliest signing event. (xx/xx/xx)

7000-1892

6/12/2019

Waived/Exception Granted

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Compliance

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  PA Application Disclosure, PA Mortgage Loan Rate Lock Agreement and PA Notice Regarding Refund ability of Fees.

7000-1893

6/11/2019

Waived/Exception Granted

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Compliance

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Loan Estimate signed on XXXX does not reflect the date issued.

7000-1894

6/12/2019

Waived/Exception Granted

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Compliance

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Allow use of rental income of $2,691.85 per month Gross and $267 net from XXXX for 2018 without being reported on 2018 1040s.Compensating Factors:1.643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2.DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines3.Borrower has been in same line of work for the last 25 years

7000-1880

6/10/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Credit

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537546

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Less than 3 months seasoning. Home purchased on XXX via XXX. Current file closed XXX.Compensating Factors:1.643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2.DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines3.Borrower has been in same line of work for the last 25 years

7000-1881

6/10/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 643 credit score; 3 points above minimum credit score of 640 as required by guidelines 2. DTI of 46.44%, 3.56% lower than the max DTI of 50.00% as required in the guidelines 3. Borrower has been in same line of work for the last 25 years

Waived

Credit

EG2

6/10/2019

Primary Residence

PA

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537548

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Points increased on Loan Estimate dated XXXX and Appraisal Fee increased on Closing Disclosure dated XXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $179.48.

7000-2500

8/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/13/2019: Received xx/xx/xxxx COC reflecting the re-lock with terms as reflected on the xx/xx/xxxx LE. With the COC accounted for, the loan met the TRID reimbursement test.

Compensating Factors: 1. Owner of the same business for 30 years 2. No public records 3. All tradelines paid as agreed since earliest account inception dated 07/2003

Cured

Compliance

EG1

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537548

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1 This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $37.15, is not sufficient to reimburse the consumer the amount by which the tolerances were exceeded, $179.48.

7000-2501

8/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/13/2019: Received xx/xx/xxxx COC for loan re-loc as reflected on the xx/xx/xxxx LE. The loan now passes TRID reimbursement test.

Compensating Factors: 1. Owner of the same business for 30 years 2. No public records 3. All tradelines paid as agreed since earliest account inception dated 07/2003

Cured

Compliance

EG1

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537548

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing August 2018 bank statement from XXX Bank account ending in xxxx. Loan is subject to income recalculation

7000-2506

8/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

8/13/19: Received August 2018 bank statement. DTI within guidelines.

Compensating Factors: 1. Owner of the same business for 30 years 2. No public records 3. All tradelines paid as agreed since earliest account inception dated 07/2003

Cured

Credit

EG1

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537548

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception due to credit score is 671 vs program requirement of 680Compensating Factors:1. Owner of the same business for 30 years2. No public records3. All tradelines paid as agreed since earliest account inception dated 07/2003

7000-2508

8/8/2019

Waived/Exception Granted

8/8/19: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. Owner of the same business for 30 years 2. No public records 3. All tradelines paid as agreed since earliest account inception dated 07/2003

Waived

Credit

EG2

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537548

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing evidence of gift funds transfer of $xx,xxx.xx with copy of borrower's deposit slip, donor's check to the closing agent, or settlement statement showing receipt of the donors check.   /// UPDATED 8/20/19:  duplicate copy of XXXX xxxxxx (donor account) has been received.  Wire to escrow from borrower's account has been received.  Still missing evidence the donor's give was wired to the borrower's account. //  UPDATED 9/10/2019: Received New gift letter amending gift amount to $x,xxx.xx and borrower statement showing receipt of the $x,xxx.xx dated 7/29/2019.  New reserves calculation now short: Total assets $xx,xxx.xx (XXXX xxxxxx - includes $x,xxx gift funds) less total cash into transaction $xx,xxx.xx = shortage $4,466.67 /// UPDATE 9/12/2019 Received XXXX xxxxxx end date 8/12/2019.  Used available bal of $xx,xxx.xx as of 7/29/20196(prior to close of loan).  Updated asset calc: $xx,xxx.xx(includes gift funds of $xxxx) less total cast into transaction $xx,xxx.xx = net reserves $260.41 and insufficient to meet 3 month requirement. \\\\ Update 9/19/2019 Client exception for reserves received.

7000-2509

9/19/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. Owner of the same business for 30 years 2. No public records 3. All tradelines paid as agreed since earliest account inception dated 07/2003

Cured

Credit

EG1

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537548

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception for reserves not meeting program requirements. Compensating Factors:1. Owner of the same business for 30 years2. No public records3. All tradelines paid as agreed since earliest account inception dated 07/2003

7000-3088

9/19/2019

Waived/Exception Granted

Compensating Factors: 1. Owner of the same business for 30 years 2. No public records 3. All tradelines paid as agreed since earliest account inception dated 07/2003

Waived

Credit

EG2

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430592931

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2115

7/2/2019

Waived/Exception Granted

Compensating Factors: 1. 716 credit score; 36 points above minimum credit score of 680 as required by guidelines 2. 17 months reserves; 14 months greater than 3 months reserves required 3. DTI of 42.26%, 7.74% lower than the max DTI of 50.00% as required in the guidelines 4. Housing history is 0x30 for 12 months

Waived

Compliance

EG2

6/27/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592931

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing Use of Funds letter from CPA regarding use of business assets in XXXX Business checking, account xxxxxx and xxxxxx, and the impact, if any, it would have on the borrower's business.

7000-2132

7/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Not required as borrower has sufficient own funds.

Compensating Factors: 1. 716 credit score; 36 points above minimum credit score of 680 as required by guidelines 2. 17 months reserves; 14 months greater than 3 months reserves required 3. DTI of 42.26%, 7.74% lower than the max DTI of 50.00% as required in the guidelines 4. Housing history is 0x30 for 12 months

Cured

Credit

EG1

6/27/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592931

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing legible  page 1 of 9 of Deed of Trust. Page 1 in file is cut off by another page.

7000-2133

7/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 07/02/2019: Received a leglible copy of page 1 of the subject security instrument.

Compensating Factors: 1. 716 credit score; 36 points above minimum credit score of 680 as required by guidelines 2. 17 months reserves; 14 months greater than 3 months reserves required 3. DTI of 42.26%, 7.74% lower than the max DTI of 50.00% as required in the guidelines 4. Housing history is 0x30 for 12 months

Cured

Credit

EG1

6/27/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592931

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing signature and notary pages of the General Warranty Agreement.

7000-2134

7/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 07/02/2019: Received signature and notary pages of the General Warranty Deed.

Compensating Factors: 1. 716 credit score; 36 points above minimum credit score of 680 as required by guidelines 2. 17 months reserves; 14 months greater than 3 months reserves required 3. DTI of 42.26%, 7.74% lower than the max DTI of 50.00% as required in the guidelines 4. Housing history is 0x30 for 12 months

Cured

Compliance

EG1

6/27/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430518311

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client Approved Exception: DTI is 57.748% vs program guideline maximum DTI of 50.00%Compensating Factors:1. 766 FICO, 86 points greater than program guideline minimum FICO of 6802. 80.00% LTV, 10% less than program guideline maximum LTV of 90.00%3. 22 months reserves vs 3 months program guideline reserves requirement

7000-1662

5/28/2019

Waived/Exception Granted

05/28/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 766 FICO, 86 points greater than program guideline minimum FICO of 680 2. 80.00% LTV, 10% less than program guideline maximum LTV of 90.00% 3. 22 months reserves vs 3 months program guideline reserves requirement

Waived

Credit

EG2

5/28/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430518311

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure, TX Designation of Homestead and Affidavit, TX Lock-In Agreement and TX Mortgage Company Disclosure.

7000-1664

5/30/2019

Waived/Exception Granted

Compensating Factors: 1. 766 FICO, 86 points greater than program guideline minimum FICO of 680 2. 80.00% LTV, 10% less than program guideline maximum LTV of 90.00% 3. 22 months reserves vs 3 months program guideline reserves requirement

Waived

Compliance

EG2

5/28/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430518311

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception; excluded XXXX account ending xxxx without evidence of vehicle return prior to closing. Compensating Factors: 1. FICO 766 exceeds minimum required of 640. 2. +24 years in same line of work (xxxx).3. 23.55  months reserves exceed minimum requirement.

7000-2460

7/30/2019

Waived/Exception Granted

Seller opted to waive requirement.

Compensating Factors: 1. 766 FICO, 86 points greater than program guideline minimum FICO of 680 2. 80.00% LTV, 10% less than program guideline maximum LTV of 90.00% 3. 22 months reserves vs 3 months program guideline reserves requirement

Waived

Credit

EG2

5/28/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537549

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

UPDATE The loan contains errors within one or more TRID disclosure. The Lender NMLS ID number listed on the note, mortgage, and the XXX final CD, #XXXX, is associated with XXXX and not XXXX. Need corrected note and mortgage with re-opened rescission period, reflecting XXX's correct NMLS ID number on the legal documents. Also, need Post Consummation Closing Disclosure with borrower letter, re-opened rescission, and proof of delivery, reflecting the corrected Lender NMLS ID number.

7000-2682

8/21/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

Received new RoR along with corrected CD disclosing the correct NMLS # for the lender.

Compensating Factors: 1. 767 credit score; 47 points above minimum credit score of 720 as required by guidelines 2. 86.293% LTV; 3.707% below 90% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been self-employed for the last 5 years 6. DTI ratio of 40%; 10% less than 50% maximum

Cured

Compliance

EG2

8/16/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537549

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-2639

8/20/2019

Waived/Exception Granted

Compensating Factors: 1. 767 credit score; 47 points above minimum credit score of 720 as required by guidelines 2. 86.293% LTV; 3.707% below 90% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been self-employed for the last 5 years 6. DTI ratio of 40%; 10% less than 50% maximum

Waived

Compliance

EG2

8/16/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537550

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception in file. Exception to use secondary employment income. Compensating Factors:1.703 credit score; 23 points above minimum credit score of 680 as required by guidelines 2.Borrower has been employed for the last 10 years

7000-2835

8/28/2019

Waived/Exception Granted

Compensating Factors: 1. 703 credit score; 23 points above minimum credit score of 680 as required by guidelines 2. Borrower has been employed for the last 10 years

Waived

Credit

EG2

6/4/2019

Second Home

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537550

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure and Lender's Privacy Policy.

7000-1766

6/6/2019

Waived/Exception Granted

Compensating Factors: 1. 703 credit score; 23 points above minimum credit score of 680 as required by guidelines 2. Borrower has been employed for the last 10 years

Waived

Compliance

EG2

6/4/2019

Second Home

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537550

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved the allowance of the use of the appraisal report with appraisal transfer letter that does not meet all XXX requirements for transfer letter.Compensating Factors:1.703 credit score; 23 points above minimum credit score of 680 as required by guidelines 2.Borrower has been employed for the last 10 years

7000-1764

6/4/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 703 credit score; 23 points above minimum credit score of 680 as required by guidelines 2. Borrower has been employed for the last 10 years

Waived

Credit

EG2

6/4/2019

Second Home

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537550

XXXX

XXXX

XXXX

Credit - Income and Assets

DTI is 68.46%. Borrower does not have satisfactory history of secondary employment income as required by XXX guidelines.

7000-1783

8/28/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

allowed 2nd job income

Compensating Factors: 1. 703 credit score; 23 points above minimum credit score of 680 as required by guidelines 2. Borrower has been employed for the last 10 years

Cured

Credit

EG1

6/4/2019

Second Home

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537550

XXXX

XXXX

XXXX

Credit - Insurance and Title

Missing copy of cost to rebuild estimate from insurance company to confirm coverage listed of $xx,xxx is sufficient. Current policy is short of minimum dwelling coverage of $xxx,xxx.xx. Subject to recalculation of debt ratios.

7000-1776

6/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

received rebuild estimate from insurance company that indicates $xx,xxxx.xx which is sufficient

Compensating Factors: 1. 703 credit score; 23 points above minimum credit score of 680 as required by guidelines 2. Borrower has been employed for the last 10 years

Cured

Credit

EG1

6/4/2019

Second Home

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537550

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing copy of appraisal dated XXXX which was transferred from XXX to XXX. Appraisal in file is dated XXX. Subject to review and additional conditions.

7000-1778

6/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

06/20/2019: Received transfer of Class Appraisal to xxxx for appraisal dated xx/xx/xxxx; appraisal in file.

Compensating Factors: 1. 703 credit score; 23 points above minimum credit score of 680 as required by guidelines 2. Borrower has been employed for the last 10 years

Cured

Credit

EG1

6/4/2019

Second Home

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537551

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing documentation to evidence that the property located at XXX has been sold. Subject to the recalculation of the debt to income ratio.

7000-2700

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 653 credit score; 13 points above minimum credit score of 640 as required by guidelines 2. Mortgage history is 0x30 for 12 months  3. No public records 4. Borrower has been self-employed for the last 3 years 5. DTI ratio of 24.39%; 25.61% less than 50% maximum

Cured

Credit

EG1

8/19/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537551

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure (CD) in file dated XXX is missing all of the Seller Paid fees according to the Seller's Closing Disclosure in file dated XXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-2685

8/21/2019

Waived/Exception Granted

Compensating Factors: 1. 653 credit score; 13 points above minimum credit score of 640 as required by guidelines 2. Mortgage history is 0x30 for 12 months  3. No public records 4. Borrower has been self-employed for the last 3 years 5. DTI ratio of 24.39%; 25.61% less than 50% maximum

Waived

Compliance

EG2

8/19/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537553

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On the Post Consummation Closing Disclosure issued XXX, under the "Loan Terms" section on Page 1, "Prepayment Penalty" reflects "No," however, there is a Prepayment Addendum to the Note in file dated XXX and a Prepayment Rider attached to the Mortgage in file dated XXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting a Prepayment Penalty with re-opened rescission period.

7000-1955

7/10/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 07/10/2019: Re-opened rescission passed without incident.

Compensating Factors: 1. 775 FICO, 75 points greater than program guideline minimum FICO of 680 2. 80.00 % LTV, 10% less than program guideline maximum LTV of 90.00% 3. Owner of a business for 5 years

Cured

Compliance

EG2

6/13/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537553

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On CD issued XXX, under the Estimated Taxes, Insurance and Assessments section on page one, This estimate includes, Other is missing a description of the other assessments that are not in escrow.  Need Post Consummation CD with a description of the other assessments that are not in escrow and explanation letter to borrower with proof of method of delivery of all to borrower.

7000-1956

6/21/2019

Waived/Exception Granted

Compensating Factors: 1. 775 FICO, 75 points greater than program guideline minimum FICO of 680 2. 80.00 % LTV, 10% less than program guideline maximum LTV of 90.00% 3. Owner of a business for 5 years

Waived

Compliance

EG2

6/13/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537553

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  Missing explanation letter to borrower and proof of method of delivery for Post Consummation CD in file dated XXX.

7000-1960

7/10/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 07/10/2019: Received Lender attestation, indicating 06/06/2019 was not disclosed to the borrower; ComplianceEase was updated.

Compensating Factors: 1. 775 FICO, 75 points greater than program guideline minimum FICO of 680 2. 80.00 % LTV, 10% less than program guideline maximum LTV of 90.00% 3. Owner of a business for 5 years

Cured

Compliance

EG1

6/13/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537553

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

EdgeMAC does not consider negative per diem interest as a credit against the total finance charge.  Please provide a PCCD with letter of explanation and proof of method of delivery to the borrower that discloses the prepaid interest amount in line F03 as $0.00 and use an offsetting lender credit in section H with a description of applicability to under disclosed finance charges to properly apply the credit and accurately disclose the credit to finance charges.TILA Post-Consummation Revised Closing Disclosure Lending PoliciesThis loan failed the TILA finance charge test.(12 CFR 1026.18(d)(1), transferred from 12 CFR 226.18(d)(1))The finance charge is $xxx,xxx.xx. The disclosed finance charge of $xxx,xxx.xx is not considered accurate because it is understated by more than $100.00.  Total under disclosed amount is -$423.50.

7000-1965

6/21/2019

Waived/Exception Granted

Compensating Factors: 1. 775 FICO, 75 points greater than program guideline minimum FICO of 680 2. 80.00 % LTV, 10% less than program guideline maximum LTV of 90.00% 3. Owner of a business for 5 years

Waived

Compliance

EG2

6/13/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537553

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  On the revised Loan Estimate (LE) in file dated XXX the "Broker Fee" increased without a valid Change of Circumstance, resulting in the below TRID Tolerance Violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $160.00.

7000-1966

6/18/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 06/18/2019: Received 05/08/2019 COC for loan amount increase/lock.

Compensating Factors: 1. 775 FICO, 75 points greater than program guideline minimum FICO of 680 2. 80.00 % LTV, 10% less than program guideline maximum LTV of 90.00% 3. Owner of a business for 5 years

Cured

Compliance

EG1

6/13/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537553

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing 2018 W2 from XXX and current Pay stub covering 30 days with YTD earnings. //UPDATE 07/29:  Using only 2017 W-2 income, DTI is 214%, which exceeds guidelines and the Client approved exception of 55.372%.  2019 YTD Income Ledger from XXX shows borrower paid himself more wages.  Missing 2018 W-2 XXX or additional income documentation to support 55.372% DTI. ///  Recalculated income using 2017 earnings is $x,xxx.xx/month and DTI of 58.53%

7000-2003

Compensating Factors: 1. 775 FICO, 75 points greater than program guideline minimum FICO of 680 2. 80.00 % LTV, 10% less than program guideline maximum LTV of 90.00% 3. Owner of a business for 5 years

Open

Credit

EG2

6/13/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537553

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing 2018 personal tax return filings of proof of extension.

7000-1976

6/18/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

received 2018 tax extension filing

Compensating Factors: 1. 775 FICO, 75 points greater than program guideline minimum FICO of 680 2. 80.00 % LTV, 10% less than program guideline maximum LTV of 90.00% 3. Owner of a business for 5 years

Cured

Credit

EG1

6/13/2019

Primary Residence

MI

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537554

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Need New Final Signed 1003 Loan Application for XXXX reflecting accurate box marked for item "l" in Section VIII. Declarations.  Both copies of Final Signed 1003 Loan Applications in file for XXXX reflect she does intend to occupy the property as her primary residence, however, file has been submitted as "Investment Property".

7000-2571

9/13/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 09/13/2019: Received corrected page 3 of 4 of the final loan application signed by co-borrower, reflecting co-borrower does not intend to occupy subject property. The signed page is new and does not match any of the other loan applications the co-borrower previously signed.

Compensating Factors: 1. Mortgage history is 0x30 for 12 months   2. No public records 3. Borrower has been self-employed for the last 4.5 years; co-borrower the last 9 years

Cured

Compliance

EG2

8/15/2019

Investment Property

WI

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537554

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception for the loan amount of $XXXX being less than the program required minimum loan amount of $75,00.00.Compensating Factors:1. Mortgage history is 0x30 for 12 months  2. No public records3. Borrower has been self-employed for the last 4.5 years; co-borrower the last 9 years

7000-2630

8/15/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. Mortgage history is 0x30 for 12 months   2. No public records 3. Borrower has been self-employed for the last 4.5 years; co-borrower the last 9 years

Waived

Credit

EG2

8/15/2019

Investment Property

WI

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537554

XXXX

XXXX

XXXX

Credit - Income and Assets

Client approved exception for the DTI ratio of 55.369% exceeding the program maximum of 50%.Compensating Factors:1. Mortgage history is 0x30 for 12 months  2. No public records3. Borrower has been self-employed for the last 4.5 years; co-borrower the last 9 years

7000-2635

8/15/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. Mortgage history is 0x30 for 12 months   2. No public records 3. Borrower has been self-employed for the last 4.5 years; co-borrower the last 9 years

Waived

Credit

EG2

8/15/2019

Investment Property

WI

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537555

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure (CD) in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-1938

6/18/2019

Waived/Exception Granted

Compensating Factors: 1. 6.278% DTI, 36.722% less than program guideline maximum DTI of 43.00% 2. 5 month reserves, 2 months greater than program guideline 3 months reserves requirement 3. Owner of the same business  for 4 years

Waived

Compliance

EG2

6/12/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537555

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Grant Deed to confirm vesting on Mortgage.

7000-1939

6/17/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 06/17/2019: Received Warranty Deed.

Compensating Factors: 1. 6.278% DTI, 36.722% less than program guideline maximum DTI of 43.00% 2. 5 month reserves, 2 months greater than program guideline 3 months reserves requirement 3. Owner of the same business  for 4 years

Cured

Compliance

EG1

6/12/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537555

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-1940

6/13/2019

Waived/Exception Granted

Compensating Factors: 1. 6.278% DTI, 36.722% less than program guideline maximum DTI of 43.00% 2. 5 month reserves, 2 months greater than program guideline 3 months reserves requirement 3. Owner of the same business  for 4 years

Waived

Compliance

EG2

6/12/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537555

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

EdgeMAC does not consider negative per diem interest as a credit against the total finance charge.  Please provide a PCCD with letter of explanation and proof of method of delivery to the borrower that discloses the prepaid interest amount in line F03 as $0.00 and use an offsetting lender credit in section H with a description of applicability to under disclosed finance charges to properly apply the credit and accurately disclose the credit to finance charges.Federal TILAThis loan failed the TILA finance charge test.(12 CFR 1026.18(d)(1), transferred from 12 CFR 226.18(d)(1))The finance charge is $xxx,xxx.xx. The disclosed finance charge of $xxx,xxx.xx is not considered accurate because it is understated by more than $100.00.  Total under disclosed amount is -$157.40.

7000-1942

6/18/2019

Waived/Exception Granted

Compensating Factors: 1. 6.278% DTI, 36.722% less than program guideline maximum DTI of 43.00% 2. 5 month reserves, 2 months greater than program guideline 3 months reserves requirement 3. Owner of the same business  for 4 years

Waived

Compliance

EG2

6/12/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537557

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2467

8/2/2019

Waived/Exception Granted

Compensating Factors: 1. 18.935% DTI, 24.065% less than program guideline maximum DTI of 43.00% 2. 739 FICO, 59 points greater than program guideline minimum FICO of 680 3. 6 months reserves, 3 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 2 years

Waived

Compliance

EG2

8/1/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537557

XXXX

XXXX

XXXX

Property - Collateral

Missing copy of appraisal for subject property purchase transaction. Subject to review.

7000-2468

8/2/2019

Property condition cleared

Full appraisal has been added to the file

Compensating Factors: 1. 18.935% DTI, 24.065% less than program guideline maximum DTI of 43.00% 2. 739 FICO, 59 points greater than program guideline minimum FICO of 680 3. 6 months reserves, 3 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 2 years

Cured

Property

EG1

8/1/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537557

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

UPDATE // 8/2/2019: Received CoC dated XXXX referencing the addition of points in the amount of .15% ($223.00), what is needed is the corresponding CoC for the increase in points on the XXXX LE in the amount of $ 594.00This loan failed TRID zero fee tolerance.  Points increased on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $371.00.

7000-2469

8/5/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/05/2019: Received 07/22/2019 COC.

Compensating Factors: 1. 18.935% DTI, 24.065% less than program guideline maximum DTI of 43.00% 2. 739 FICO, 59 points greater than program guideline minimum FICO of 680 3. 6 months reserves, 3 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for 2 years

Cured

Compliance

EG1

8/1/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430518334

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure (CD) in file dated XXXX do not match the Seller Paid fees on the XXX Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-1681

6/13/2019

Waived/Exception Granted

Compensating Factors: 1. 738 FICO, 58 points greater than program guideline minimum FICO of 680 2. 14 months reserves vs 3 months program guideline reserves requirement 3. 5 years as self employed 4. 85.00% LTV, 5% less than program guideline maximum LTV of 90.00%

Waived

Compliance

EG2

5/29/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430518334

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing verification of self employment for a minimum of 2 continuous years using Business License, CPA Letter or Regulatory Agency.

7000-1692

6/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

IMDB and 1099 rcvd

Compensating Factors: 1. 738 FICO, 58 points greater than program guideline minimum FICO of 680 2. 14 months reserves vs 3 months program guideline reserves requirement 3. 5 years as self employed 4. 85.00% LTV, 5% less than program guideline maximum LTV of 90.00%

Cured

Credit

EG1

5/29/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430518334

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client Approved Exception: DTI is 55.149% vs program guideline maximum DTI of 50.00%Compensating Factors:1. 738 FICO, 58 points greater than program guideline minimum FICO of 6802. 14 months reserves vs 3 months program guideline reserves requirement 3. 5 years as self employed 4. 85.00% LTV, 5% less than program guideline maximum LTV of 90.00%

7000-1685

5/29/2019

Waived/Exception Granted

Client opted to waive guideline requirement.

Compensating Factors: 1. 738 FICO, 58 points greater than program guideline minimum FICO of 680 2. 14 months reserves vs 3 months program guideline reserves requirement 3. 5 years as self employed 4. 85.00% LTV, 5% less than program guideline maximum LTV of 90.00%

Waived

Credit

EG2

5/29/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537558

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  TX Mortgage Company Disclosure.

7000-2143

7/8/2019

Waived/Exception Granted

Compensating Factors: 1. 20.20% DTI, 22.80% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 14 years 3. 700 FICO, 20 points greater than program guideline minimum FICO of 680 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

7/5/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537559

XXXX

XXXX

XXXX

Credit - Insurance and Title

Missing updated hazard/homeowners insurance policy to reflects replacement costs to rebuild value

7000-1887

6/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Binder rcvd

Compensating Factors 1. 38.12% DTI, 11.88% less than program guideline maximum DTI of 50.00% 2. 67.500% LTV, 12.50% less than program guideline maximum LTV of 80.00% 3. 687 FICO, 27 points greater than program guideline minimum FICO of 660 4. 34 months reserves, 31 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

6/12/2019

Primary Residence

TX

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430537559

XXXX

XXXX

XXXX

Property - Collateral

Loan approval is subject to satisfactory appraisal review.  Subject to further underwriting.  Additional conditions may apply.Missing required CDA per XXXX Guidelines.

7000-1910

6/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

CDA rcvd

Compensating Factors 1. 38.12% DTI, 11.88% less than program guideline maximum DTI of 50.00% 2. 67.500% LTV, 12.50% less than program guideline maximum LTV of 80.00% 3. 687 FICO, 27 points greater than program guideline minimum FICO of 660 4. 34 months reserves, 31 months greater than program guideline 3 months reserves requirement

Cured

Property

EG1

6/12/2019

Primary Residence

TX

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430537559

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure, TX Homestead Owners Pre-Closing Fee Disclosure Affidavit, TX Lock-In Agreement, and TX Mortgage Company Disclosure.

7000-1897

6/12/2019

Waived/Exception Granted

Compensating Factors 1. 38.12% DTI, 11.88% less than program guideline maximum DTI of 50.00% 2. 67.500% LTV, 12.50% less than program guideline maximum LTV of 80.00% 3. 687 FICO, 27 points greater than program guideline minimum FICO of 660 4. 34 months reserves, 31 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

6/12/2019

Primary Residence

TX

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430537559

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

EdgeMAC does not consider negative per diem interest as a credit against the total finance charge.  Please provide a PCCD with letter of explanation and proof of method of delivery to the borrower that discloses the prepaid interest amount in line F03 as $0.00 and use an offsetting lender credit in section H with a description of applicability to under disclosed finance charges to properly apply the credit and accurately disclose the credit to finance charges.Federal TILAThis loan failed the TILA finance charge test.(12 CFR 1026.18(d)(1), transferred from 12 CFR 226.18(d)(1))The finance charge is $xxx,xxx.xx. The disclosed finance charge of $xxx,xxx.xx is not considered accurate because it is understated by more than $100.00.  Total under disclosed amount is -$137.68, which is a $0.14 variance from the per diem interest credit noted on the final Closing Disclosure of -$137.82.

7000-1900

6/13/2019

Waived/Exception Granted

Compensating Factors 1. 38.12% DTI, 11.88% less than program guideline maximum DTI of 50.00% 2. 67.500% LTV, 12.50% less than program guideline maximum LTV of 80.00% 3. 687 FICO, 27 points greater than program guideline minimum FICO of 660 4. 34 months reserves, 31 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

6/12/2019

Primary Residence

TX

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430537559

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure (CD) in file dated XXXX contains inaccurate ETIA information on Page 1 and Escrow Account information on Page 4.  Estimated Escrow and ETIA amount should reflect $550.84 total, reflecting Property Tax monthly amount of $274.51 according to the Tax Certificate in file and Insurance monthly amount of $276.33.  Monthly Escrow Payment on Page 4 would then be $550.84 and Escrowed Property Costs over Year 1 would be $6,610.08.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting correct ETIA and Escrow Account information.

7000-1901

6/17/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 06/17/2019: Received PCCD with borrower letter and proof of delivery for corrected ETIA and escrow sections.

Compensating Factors 1. 38.12% DTI, 11.88% less than program guideline maximum DTI of 50.00% 2. 67.500% LTV, 12.50% less than program guideline maximum LTV of 80.00% 3. 687 FICO, 27 points greater than program guideline minimum FICO of 660 4. 34 months reserves, 31 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

6/12/2019

Primary Residence

TX

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430537559

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Subject has xx.xx acres vs program guideline maximum of 15 acresCompensating Factors1. 38.12% DTI, 11.88% less than program guideline maximum DTI of 50.00%2. 67.500% LTV, 12.50% less than program guideline maximum LTV of 80.00%3. 687 FICO, 27 points greater than program guideline minimum FICO of 6604. 34 months reserves, 31 months greater than program guideline 3 months reserves requirement

7000-1947

6/12/2019

Waived/Exception Granted

Seller opted to waive requirement.

Compensating Factors 1. 38.12% DTI, 11.88% less than program guideline maximum DTI of 50.00% 2. 67.500% LTV, 12.50% less than program guideline maximum LTV of 80.00% 3. 687 FICO, 27 points greater than program guideline minimum FICO of 660 4. 34 months reserves, 31 months greater than program guideline 3 months reserves requirement

Waived

Credit

EG2

6/12/2019

Primary Residence

TX

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430537560

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing source of the following large deposits into borrower's XXXX, account ending xxxxxx: $xx,xxx.xx on 04/01/2019. Deposit used for transfer to XXXX, account ending xxxxxx, on 04/03/2019. Subject to recalculation of assets.

7000-2314

7/24/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Proceeds from sale of xxxx - HUD 1 in file.

Compensating Factors: 1. 33.52% DTI, 16.48% less than program guideline maximum DTI of 50.00% 2. 717 FICO, 77 points greater than program guideline minimum of 640 3. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

7/18/2019

Second Home

HI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537560

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Mortgage/Deed of Trust dated XXXX.  Unable to complete regulatory compliance review.

7000-2287

7/23/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Received signed/dated DOT complete with legal and riders

Compensating Factors: 1. 33.52% DTI, 16.48% less than program guideline maximum DTI of 50.00% 2. 717 FICO, 77 points greater than program guideline minimum of 640 3. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG1

7/18/2019

Second Home

HI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537560

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure in file dated XXXX contains inaccurate ETIA on page 1 and Estimated Property Costs over Year 1 on page 4.  ETIA on Page one should reflect $282.31 Total.  Property Tax Monthly amount is $216.53, Insurance Monthly amount is $42.00, Windstorm Ins is 23.78. Estimated Property Costs over Year 1 would then be $3,387.72  Unable to obtain HOA fees as not stated on appraisal, however, noted on ETIA as some HOA was included.  Need Post Consummation Closing disclosure with explanation letter to borrower and proof of method of delivery to borrower reflecting accurate ETIA and Estimated Property Costs over Year 1.

7000-2288

7/23/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

Received PCCD along with LOE and POD reflecting correct ETIA/escrow amounts. Fee description on page 1 is still incorrect (rreflects HOA not wind/storm), but non-material in scope

Compensating Factors: 1. 33.52% DTI, 16.48% less than program guideline maximum DTI of 50.00% 2. 717 FICO, 77 points greater than program guideline minimum of 640 3. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

7/18/2019

Second Home

HI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537560

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. Closing Disclosure in file dated XXXX is missing the Seller paid fees according to the Seller's CD in file dated XXXX.  Need Post Consummation CD with letter to borrower and proof of method of delivery to borrower reflecting all Seller paid fees.

7000-2299

7/23/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Received PCCD reflecting seller paid fees

Compensating Factors: 1. 33.52% DTI, 16.48% less than program guideline maximum DTI of 50.00% 2. 717 FICO, 77 points greater than program guideline minimum of 640 3. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG1

7/18/2019

Second Home

HI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537561

XXXX

XXXX

XXXX

Credit - Insurance and Title

Missing copy of cost to rebuild estimate from insurance company to confirm coverage listed of $xxx,xxx is sufficient. Current policy is short of minimum dwelling coverage of $xxx,xxx. Subject to recalculation of debt ratios.

7000-2008

6/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Updated Hazard Ins with $192K dwelling + $19,200 other structures.

Compensating Factors: 1. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. No public records 4. Owner of the same business for 2 years 5. 48.21% DTI, 1.79% less than program guideline maximum DTI of 50.00%

Cured

Credit

EG1

6/17/2019

Primary Residence

CT

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537561

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-2021

6/20/2019

Waived/Exception Granted

Compensating Factors: 1. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. No public records 4. Owner of the same business for 2 years 5. 48.21% DTI, 1.79% less than program guideline maximum DTI of 50.00%

Waived

Compliance

EG2

6/17/2019

Primary Residence

CT

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537561

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  On the revised Closing Disclosure (CD) in file dated XXXX the "Points" increased to a final amount of $616.00 from the initial amount of $312.00 without a valid Change of Circumstance, resulting in the below TRID Tolerance Violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $304.00.

7000-2022

6/21/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 06/21/2019: Received 05/15/2019 and 06/03/2019 COC's addressing point increases.

Compensating Factors: 1. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. No public records 4. Owner of the same business for 2 years 5. 48.21% DTI, 1.79% less than program guideline maximum DTI of 50.00%

Cured

Compliance

EG1

6/17/2019

Primary Residence

CT

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537561

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

CT Nonprime Home Loan Lending PoliciesThis loan failed the CT nonprime home loan test.  The loan is a nonprime home loan, as defined in the legislation.

7000-2023

6/20/2019

Waived/Exception Granted

Compensating Factors: 1. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. No public records 4. Owner of the same business for 2 years 5. 48.21% DTI, 1.79% less than program guideline maximum DTI of 50.00%

Waived

Compliance

EG2

6/17/2019

Primary Residence

CT

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537561

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Loan is considered CT NonPrime Loan is missing the Additional Notice of Loan Terms Disclosure required by Conn. Gen. Stat.  36a-760a

7000-2044

6/20/2019

Waived/Exception Granted

Compensating Factors: 1. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. No public records 4. Owner of the same business for 2 years 5. 48.21% DTI, 1.79% less than program guideline maximum DTI of 50.00%

Waived

Compliance

EG2

6/17/2019

Primary Residence

CT

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430518338

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure dated XXXX is Missing most of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-1633

5/28/2019

Waived/Exception Granted

Compensating Factors: 1. 243 months reserves vs 5 months program guideline reserves requirement 2. Excellent mortgage payment history since origination 3. 48.24% DTI, 1.76% less than program guideline maximum DTI of 50.00

Waived

Compliance

EG2

5/24/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430518338

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  IL Loan Brokerage Agreement and IL Loan Brokerage Disclosure Statement.

7000-1634

5/28/2019

Waived/Exception Granted

Compensating Factors: 1. 243 months reserves vs 5 months program guideline reserves requirement 2. Excellent mortgage payment history since origination 3. 48.24% DTI, 1.76% less than program guideline maximum DTI of 50.00

Waived

Compliance

EG2

5/24/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537562

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: 100% of the earnest money deposit and funds to close are coming from a gift vs program requirement that at least 5% of the purchase transaction must be from borrower's own funds when there is a non-occupant co-borrowerCompensating Factors:1. 23.36% DTI, 26.64% less than program guideline maximum DTI of 50.00%2. 670 FICO score, 30 points greater than program guideline minimum FICO of 6403. 45 months reserves, 40 months greater than program guideline 5 months reserves requirement4. No public records for both borrowers

7000-2772

8/22/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 23.36% DTI, 26.64% less than program guideline maximum DTI of 50.00% 2. 670 FICO score, 30 points greater than program guideline minimum FICO of 640 3. 45 months reserves, 40 months greater than program guideline 5 months reserves requirement 4. No public records for both borrowers’

Waived

Credit

EG2

8/22/2019

Primary Residence

IN

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430537563

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure (CD) in file dated XXXX do not match the Seller Paid fees on the Master Statement in file dated XXXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-1779

6/7/2019

Waived/Exception Granted

Compensating Factors: 1. 709 credit score; 29 points above minimum credit score of 680 as required by guidelines 2. DTI of 25.56%, 17.44% lower than the max DTI of 43.00% as required in the guidelines 3. 21 months reserves after closing; only 3 months are required by guidelines

Waived

Compliance

EG2

6/5/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537563

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  IL Loan Brokerage Agreement and IL Loan Brokerage Disclosure Statement.

7000-1780

6/7/2019

Waived/Exception Granted

Compensating Factors: 1. 709 credit score; 29 points above minimum credit score of 680 as required by guidelines 2. DTI of 25.56%, 17.44% lower than the max DTI of 43.00% as required in the guidelines 3. 21 months reserves after closing; only 3 months are required by guidelines

Waived

Compliance

EG2

6/5/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537563

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  On the initial Closing Disclosure (CD) in file dated XXXX the "Broker Fee" was added without a valid change of circumstance, resulting in the below TRID Tolerance Violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $125.01.This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $125.00, is not sufficient to reimburse the consumer the amount by which the tolerances were exceeded, $125.01.  Your total tolerance violation is -$0.01.

7000-1785

6/8/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 06/08/2019: Received explanation with initial LE system detail print out evidencing disclosure of $0.01 Mortgage Broker Fee.

Compensating Factors: 1. 709 credit score; 29 points above minimum credit score of 680 as required by guidelines 2. DTI of 25.56%, 17.44% lower than the max DTI of 43.00% as required in the guidelines 3. 21 months reserves after closing; only 3 months are required by guidelines

Cured

Compliance

EG1

6/5/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537565

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing US Visa for both borrowers.

7000-2017

7/18/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

US VISA valid for both borrowers

Compensating Factors: 1. 13.82% DTI, 36.18% less than program guideline maximum DTI of 50.00% 2. Owner of the same business for 2 years

Cured

Credit

EG1

6/18/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537565

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2027

6/20/2019

Waived/Exception Granted

Compensating Factors: 1. 13.82% DTI, 36.18% less than program guideline maximum DTI of 50.00% 2. Owner of the same business for 2 years

Waived

Compliance

EG2

6/18/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537566

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-2516

8/13/2019

Waived/Exception Granted

Compensating Factors: 1. 22.02% DTI, 27.98% less than program guideline maximum DTI of 50.00% 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 647 FICO scores, 7 points greater than program guideline minimum FICO scores of 640 4. No public records

Waived

Compliance

EG2

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537567

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The XXXX final Closing Disclosure listed the Lender Contact as XXX, NMLS ID XXXX, email XXXX when the note and security instrument list the Lender Contact as XXXX, NMLS ID XXXX. Need Post Consummation Closing Disclosure with borrower letter and proof of delivery of all documents, reflecting the Lender Contact name, NMLS ID, and email address consistent with the Lender Contact information per the note and security instrument.

7000-2451

8/1/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/01/2019: Received PCCD, borrower letter, and proof of delivery, reflecting the correct Lender Contact information.

Compensating Factors: 1. Owner of the same business for 6 years 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

7/30/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537567

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing 12 months bank statements used to calculate qualifying income for borrower. No bank statements in file.

7000-2456

8/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

8/1/19: Received 12 months bank statements for income calculation.

Compensating Factors: 1. Owner of the same business for 6 years 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

7/30/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537567

XXXX

XXXX

XXXX

Property - Collateral

Missing copy of appraisal for subject transaction. Subject to additional conditions.

7000-2438

7/31/2019

Property condition cleared

Full appraisal has been added to the file

Compensating Factors: 1. Owner of the same business for 6 years 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement

Cured

Property

EG1

7/30/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537567

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing updated 1003 verifying borrower's legal residency status. Section VIII Declarations, on loan application, reflects the borrower is neither a U.S. citizen nor a Permanent Resident Alien. Subject to program eligibility requirements.

7000-2433

8/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

8/1/19: Received updated 1003 reflecting borrower is a U.S. Citizen.

Compensating Factors: 1. Owner of the same business for 6 years 2. 678 FICO, 18 points greater than program guideline minimum FICO of 660 3. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

7/30/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537570

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client's approved exception due to DTI is 54.049% vs program guideline maximum DTI of 50.00%Compensating Factors:1. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement2. Owner of the same business for 13 years3. No public records

7000-2153

7/8/2019

Waived/Exception Granted

07/08/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 13 years 3. No public records

Waived

Credit

EG2

7/5/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430537571

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2094

7/5/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 07/05/2019: Received PCCD, borrower letter, and proof of delivery reflecting seller fees - reconciles with seller final CD.

Compensating Factors: 1. 690 credit score; 10 points above minimum credit score of 680 as required by guidelines 2. 28 months reserves; 25 months greater than 3 months reserves required 3. No public records 4. Housing history is 0x30 for 12 months

Cured

Compliance

EG2

6/27/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537571

XXXX

XXXX

XXXX

Property - Collateral

Missing Appraisal.  Unable to determine value to establish qualifying LTV

7000-2096

7/5/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Appraisal Rcvd

Compensating Factors: 1. 690 credit score; 10 points above minimum credit score of 680 as required by guidelines 2. 28 months reserves; 25 months greater than 3 months reserves required 3. No public records 4. Housing history is 0x30 for 12 months

Cured

Property

EG1

6/27/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537571

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure in file dated XXXX may contain inaccurate ETIA on page 1 and Estimated Property Costs over Year 1 on page 4.  ETIA on Page one reflect $712.55 Total.  Property Tax Monthly amount is $537.63, Insurance Monthly amount is $149.92 and HOA amount cannot be determined as no appraisal or confirmation of amount is in file. Provided the HOA monthly is $25.00 then ETIA would be correct.   Need Proof of HOA amount or Post Consummation Closing Disclosure with explanation letter to borrower and proof of method of delivery to borrower reflecting accurate ETIA and Estimated Property Costs over Year 1.

7000-2097

7/5/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 07/05/2019: Received appraisasl report, which supported HOA, ETIA, and Escrow information listed on final CD.

Compensating Factors: 1. 690 credit score; 10 points above minimum credit score of 680 as required by guidelines 2. 28 months reserves; 25 months greater than 3 months reserves required 3. No public records 4. Housing history is 0x30 for 12 months

Cured

Compliance

EG1

6/27/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537571

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure, TX Lock In Agreement and TX Mortgage Company Disclosure.

7000-2098

6/28/2019

Waived/Exception Granted

Compensating Factors: 1. 690 credit score; 10 points above minimum credit score of 680 as required by guidelines 2. 28 months reserves; 25 months greater than 3 months reserves required 3. No public records 4. Housing history is 0x30 for 12 months

Waived

Compliance

EG2

6/27/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537571

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing the 12 months bank statements used to support the qualifying income of $xx,xxx.xx. Income could not be verified.

7000-2099

7/5/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

received 12 months business bank statements

Compensating Factors: 1. 690 credit score; 10 points above minimum credit score of 680 as required by guidelines 2. 28 months reserves; 25 months greater than 3 months reserves required 3. No public records 4. Housing history is 0x30 for 12 months

Cured

Credit

EG1

6/27/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592932

XXXX

XXXX

XXXX

Credit - Credit

Missing satisfactory mortgage rating 1x30 for past 12 months for XXXX (Lender)

7000-2074

7/5/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Letter from mortgage holder.

Compensating Factors: 1. 5.201% DTI, 44.799% less than program guideline maximum DTI of 50.00% 2. 39.024% LTV, 30.976% less than program guideline maximum LTV of 70.00% 3. 27 months reserves, 24 months greater than program guideline 3 month reserves requirement

Cured

Credit

EG1

6/26/2019

Investment Property

FL

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG1

EG3

EG1

EG1

EG1

EG1

EG1

10/30/2019

430592932

XXXX

XXXX

XXXX

Credit - Insurance and Title

Missing updated master condo insurance binder. Master binder provided expired on 06/17/2019.

7000-2087

7/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Effective Date 6/17/2019 to 06/17/2020

Compensating Factors: 1. 5.201% DTI, 44.799% less than program guideline maximum DTI of 50.00% 2. 39.024% LTV, 30.976% less than program guideline maximum LTV of 70.00% 3. 27 months reserves, 24 months greater than program guideline 3 month reserves requirement

Cured

Credit

EG1

6/26/2019

Investment Property

FL

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG1

EG3

EG1

EG1

EG1

EG1

EG1

10/30/2019

430592932

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Payoff demand reflects 1x60 day late. Payoff demand reflects payment due for 04/01/2019 plus interest from 04/01/2019 through 06/30/2019. Subject funded on xx/xx/xxxx. Guidelines allow for max 1x30 day late in past 12 months.

7000-2089

7/5/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Letter from mortgage holder.

Compensating Factors: 1. 5.201% DTI, 44.799% less than program guideline maximum DTI of 50.00% 2. 39.024% LTV, 30.976% less than program guideline maximum LTV of 70.00% 3. 27 months reserves, 24 months greater than program guideline 3 month reserves requirement

Cured

Credit

EG1

6/26/2019

Investment Property

FL

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG1

EG3

EG1

EG1

EG1

EG1

EG1

10/30/2019

430537572

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing verification of self employment for a minimum of 2 continuous years using Business License, CPA Letter or Regulatory Agency.

7000-2078

7/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

2 years of tax returns plus evidence of online presence for xxxx.

Compensating Factors: 1. 80.00% LTV, 10.00% less than program guideline maximum LTV of 90.00% 2. Owner of the same business for the past 20 years 3. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement 4. 682 FICO, 22 points greater than program guideline minimum FICO of 660

Cured

Credit

EG1

6/26/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537572

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: DTI of 50.813% vs program guideline maximum DTI of 50.00%Compensating Factors:1. 80.00% LTV, 10.00% less than program guideline maximum LTV of 90.00%2. Owner of the same business for the past 20 years3. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement 4. 682 FICO, 22 points greater than program guideline minimum FICO of 660

7000-2080

6/27/2019

Waived/Exception Granted

Seller opted to waive requirement. Max DTI 51.00%

Compensating Factors: 1. 80.00% LTV, 10.00% less than program guideline maximum LTV of 90.00% 2. Owner of the same business for the past 20 years 3. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement 4. 682 FICO, 22 points greater than program guideline minimum FICO of 660

Waived

Credit

EG2

6/26/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537572

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  CA Domestic Partnership Addendum to Uniform Residential Loan Application  application states borrower is unmarried  the one in file has no boxes marked and is not signed by borrower.

7000-2083

6/28/2019

Waived/Exception Granted

Compensating Factors: 1. 80.00% LTV, 10.00% less than program guideline maximum LTV of 90.00% 2. Owner of the same business for the past 20 years 3. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement 4. 682 FICO, 22 points greater than program guideline minimum FICO of 660

Waived

Compliance

EG2

6/26/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537575

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Document not properly executed or dated:  The county is listed on the subject security instrument as XXXX County. Evidence was in file to show that the security instrument was recorded in XXXX County and the correct county is reflected in the legal description.

7000-1993

6/17/2019

Waived/Exception Granted

Compensating Factors: 1. 697 FICO, 37 points greater than program guideline minimum FICO of 660 2. Excellent mortgage payment history since 2011 3. Owner of the same business for 2 years

Waived

Compliance

EG2

6/13/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537575

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure, NC Fee Information From Your Mortgage Broker For Your Mortgage Loan AKA Mortgage Broker Application Disclosure, and NC Rate Spread Adjustable Mortgage Loan Disclosure AKA NC Acknowledgement of Fixed Rate Loan Terms and Costs.

7000-1971

6/17/2019

Waived/Exception Granted

Compensating Factors: 1. 697 FICO, 37 points greater than program guideline minimum FICO of 660 2. Excellent mortgage payment history since 2011 3. Owner of the same business for 2 years

Waived

Compliance

EG2

6/13/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537575

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  Missing signed Lender's explanation for incomplete Closing Disclosure(s) in file missing pages and/or key data elements, however, not marked as "Draft" or "Preliminary".

7000-1972

6/17/2019

Waived/Exception Granted

Compensating Factors: 1. 697 FICO, 37 points greater than program guideline minimum FICO of 660 2. Excellent mortgage payment history since 2011 3. Owner of the same business for 2 years

Waived

Compliance

EG2

6/13/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537575

XXXX

XXXX

XXXX

Credit - Income and Assets

The verified assets of $xx,xxx.xx are insufficient to satisfy the cash to close requirement of $xx,xxx.xx and 3 months reserves requirement of $xx,xxx.xx.

7000-1983

6/17/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Sale CD reflects proceeds $xxxx. xxxx guides B3-4.3 (Verif non-depository assets)  sales proceeds using the settlement statement on the home showing sufficient net cash proceeds.

Compensating Factors: 1. 697 FICO, 37 points greater than program guideline minimum FICO of 660 2. Excellent mortgage payment history since 2011 3. Owner of the same business for 2 years

Cured

Credit

EG1

6/13/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537575

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing documentation to evidence that the property located at XXXX have been sold. Subject to debt recalculation

7000-1985

6/17/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

HUD1 provided - sale price $xxxk x/xx/xxxx.  Redfin confirmes closed sale date.

Compensating Factors: 1. 697 FICO, 37 points greater than program guideline minimum FICO of 660 2. Excellent mortgage payment history since 2011 3. Owner of the same business for 2 years

Cured

Credit

EG1

6/13/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537575

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

There is a "North Carolina General Warranty Deed" in file, however, it is incomplete.  Need fully executed Deed, inclusive of dates and signatures. Signed Closing Instructions reflecting vesting per Security Instrument and Closing Protection Letter are both in file.

7000-1987

6/17/2019

Waived/Exception Granted

Compensating Factors: 1. 697 FICO, 37 points greater than program guideline minimum FICO of 660 2. Excellent mortgage payment history since 2011 3. Owner of the same business for 2 years

Waived

Compliance

EG2

6/13/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537576

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Grant Deed to confirm vesting on Mortgage.

7000-2088

7/3/2019

Waived/Exception Granted

Compensating Factors: 1.Housing history is 0x30 for 12 months  2.No public records 3.Borrower has been self-employed for the last 21 years 4.DTI ratio of 23.66%; 26.34% less than 50% maximum

Waived

Compliance

EG2

6/27/2019

Investment Property

FL

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG1

EG2

EG2

EG3

EG1

10/30/2019

430537576

XXXX

XXXX

XXXX

Property - Collateral

Missing complete legible appraisal report with all pages. Copy of appraisal provided is cut off at the top and bottom of each page.

7000-2104

7/3/2019

Property condition cleared

Complete appraisal with all full pages has been added to the file.

Compensating Factors: 1.Housing history is 0x30 for 12 months  2.No public records 3.Borrower has been self-employed for the last 21 years 4.DTI ratio of 23.66%; 26.34% less than 50% maximum

Cured

Property

EG1

6/27/2019

Investment Property

FL

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG1

EG2

EG2

EG3

EG1

10/30/2019

430537576

XXXX

XXXX

XXXX

Credit - Legal Documentation

Missing valid notary jurat on subject security instrument due to the following: The notary jurat was completed for notarization of the Principal and not the Attorney in Fact, and did not use the Statutory Short Form of Acknowledgement for an individual acting as principal by an Attorney in Fact, in accordance with 695.25 of FL statutes.

7000-2131

7/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

7/3 Rec'd corrected copy of Mortgage.

Compensating Factors: 1.Housing history is 0x30 for 12 months  2.No public records 3.Borrower has been self-employed for the last 21 years 4.DTI ratio of 23.66%; 26.34% less than 50% maximum

Cured

Credit

EG1

6/27/2019

Investment Property

FL

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG1

EG2

EG2

EG3

EG1

10/30/2019

430537576

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing documentation to evidence the borrower current visa status

7000-2124

7/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Borrower is a foreign national and lives outside US.  He has no residency in the US.

Compensating Factors: 1.Housing history is 0x30 for 12 months  2.No public records 3.Borrower has been self-employed for the last 21 years 4.DTI ratio of 23.66%; 26.34% less than 50% maximum

Cured

Credit

EG1

6/27/2019

Investment Property

FL

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG1

EG2

EG2

EG3

EG1

10/30/2019

430537577

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing final signed CD/settlement statement.

7000-2164

7/10/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

CD rcvd

Compensating Factors: 1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00% 2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement 3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00% 4. Owners of the same business for the past 5 years for both borrowers

Cured

Credit

EG1

7/8/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537577

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Condo project not complete vs program requirement that construction must be completed in the subject phase and of all common areas and amenities designated for use by owners of units in the subject phaseCompensating Factors:1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00%2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00%4. Owners of the same business for the past 5 years for both borrowers

7000-2168

7/8/2019

Waived/Exception Granted

Seller opted to waive requirement.

Compensating Factors: 1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00% 2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement 3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00% 4. Owners of the same business for the past 5 years for both borrowers

Waived

Credit

EG2

7/8/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537577

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Condo project is currently at 46.236% sold or under contract (xx out of xx total units - with subject project having been first marketed in 04/2017) vs program guidelines minimum requirement that at least 70.00% of the units in the subject project must have been sold or under contract if the project has been marketed for more than eighteen monthsCompensating Factors:1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00%2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00%4. Owners of the same business for the past 5 years for both borrowers

7000-2169

7/10/2019

Waived/Exception Granted

Seller opted to waive requirement

Compensating Factors: 1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00% 2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement 3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00% 4. Owners of the same business for the past 5 years for both borrowers

Waived

Credit

EG2

7/8/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537577

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Points added on Closing Disclosure dated XXXX and increased on Closing Disclosure dated XXXX and Broker Fee added on Closing Disclosure dated XXXX all without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $4,304.00.

7000-2158

7/9/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 07/09/2019: Received 06/26/2019 COC, reflecting pricing change: Lower interest rate but increase to 0.50% pts and 1% broker fee of $3,130.00.

Compensating Factors: 1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00% 2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement 3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00% 4. Owners of the same business for the past 5 years for both borrowers

Cured

Compliance

EG1

7/8/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537577

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  CO Civil Union Addendum to xxxx Loan Application.  Application states borrower is unmarried.

7000-2159

7/9/2019

Waived/Exception Granted

Compensating Factors: 1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00% 2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement 3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00% 4. Owners of the same business for the past 5 years for both borrowers

Waived

Compliance

EG2

7/8/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537577

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure in file dated XXXX contains inaccurate ETIA on page 1 and Estimated Property Costs over Year 1 on page 4.  ETIA on Page one should reflect $650.57 Total.  Property Tax Monthly amount is $286.55, Insurance Monthly amount is $54.02 (per Premium increase on 06/18/2019) and HOA amount is 310.00.  Estimated Property Costs over Year 1 would then be $7,806.84.  Need Post Consummation Closing Disclosure with explanation letter to borrower and proof of method of delivery to borrower reflecting accurate ETIA and Estimated Property Costs over Year 1.

7000-2160

7/10/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 07/10/2019: Received correct HOI policy for subject property. Per Lender explanation, the initial policy included dwelling coverage which was not necessary since subject is located in a condominium project and HOA pays for dwelling on the project. The updated insurance is H06 coverage. Based on the updated insurance, ETIA and Escrow figures match the final CD.

Compensating Factors: 1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00% 2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement 3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00% 4. Owners of the same business for the past 5 years for both borrowers

Cured

Compliance

EG1

7/8/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537577

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2161

7/9/2019

Waived/Exception Granted

Compensating Factors: 1. 11.981% DTI, 38.019% less than program guidelines maximum DTI of 50.00% 2. 51 months reserves, 46 months greater than program guidelines 5 months reserves requirement 3. 79.953% LTV, 10.047% less than program guidelines maximum LTV of 90.00% 4. Owners of the same business for the past 5 years for both borrowers

Waived

Compliance

EG2

7/8/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430518351

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Mortgage Broker Fee and Transfer Taxes both increased on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation. Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $13,468.00.This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $3.75, is notsufficient to reimburse the consumer the amount by which the tolerances were exceeded, $13,468.00.

7000-2137

7/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 07/01/2019: Received 06/07/2019 COC, reflecting request to increase loan amount, as appraised value came in higher than initially estimated.

Compensating Factors: 1. 31 months reserves; 21 months greater than 10 months reserves required 2. DTI of 32.58%, 27.42% lower than the max DTI of 50.00% as required in the guidelines 3. Housing history is 0x30 for 12 months   4. 54.945% LTV; 5.055% below 60.00% maximum 5. 715 credit score; 15 points above minimum credit score of 700 as required by guidelines

Cured

Compliance

EG1

7/1/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG1

EG1

EG1

EG3

EG1

EG1

EG1

10/30/2019

430518351

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Licensing/Registration check returned the following results as of the application date of XXXX:  Loan Originator's NMLS #XXXX reflects Loan Originator is NOT Authorized to Represent Company and Loan Originator Company NMLS #XXXX is NOT Authorized to Conduct Business.

7000-2139

7/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 07/01/2019: NMLS #xxxx is associated with Loan Officer thorugh the  broker branch office xxxx

Compensating Factors: 1. 31 months reserves; 21 months greater than 10 months reserves required 2. DTI of 32.58%, 27.42% lower than the max DTI of 50.00% as required in the guidelines 3. Housing history is 0x30 for 12 months   4. 54.945% LTV; 5.055% below 60.00% maximum 5. 715 credit score; 15 points above minimum credit score of 700 as required by guidelines

Cured

Compliance

EG1

7/1/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG1

EG1

EG1

EG3

EG1

EG1

EG1

10/30/2019

430592934

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing 2018 personal tax return or evidence of extension filed. Please provide evidence of 2018 tax liability paid. ///////update///6/20/2019/////Per Seller - 1) evidence of 2018 tax liability is not required. 2) Form 4868 is not required if alternative document 9325 is provided.

7000-2052

6/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Per xxxx - OK to accept Efile confirmation form 9325 in lieu of 4868 extension form. Per xxxx - Evidence of 2018 tax liability is not required. See written confirmation.

Compensating Factors: 1. 770 FICO, 90 points greater than program guideline minimum FICO of 680 2. Owner of the same business for the past 3 years

Cured

Credit

EG1

6/11/2019

Primary Residence

HI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG2

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592934

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender Credit was removed on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - 05/30/2019 - This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits($20,570.00).This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $95.00, is notsufficient to reimburse the consumer the amount by which the tolerances were exceeded, $20,665.00.Refunds related to the good faith analysis. If amounts paid by the consumer exceed the amounts specified under 1026.19(e)(3)(i) or (ii), the creditor complies with 1026.19(e)(1)(i) if the creditor refunds the excess to the consumer no later than 60 days afterconsummation, and the creditor complies with 1026.19(f)(1)(i) if the creditor delivers or places in the mail corrected disclosuresthat reflect such refund no later than 60 days after consummation.

7000-1898

6/18/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPATE 06/18/2019: Received 05/23/2019 COC.

Compensating Factors: 1. 770 FICO, 90 points greater than program guideline minimum FICO of 680 2. Owner of the same business for the past 3 years

Cured

Compliance

EG1

6/11/2019

Primary Residence

HI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG2

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592934

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-1899

6/12/2019

Waived/Exception Granted

Compensating Factors: 1. 770 FICO, 90 points greater than program guideline minimum FICO of 680 2. Owner of the same business for the past 3 years

Waived

Compliance

EG2

6/11/2019

Primary Residence

HI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG2

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592936

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3090

9/20/2019

Waived/Exception Granted

Compensating Factors: 1. 35.43% DTI, 14.57% less than program guideline maximum DTI of 50.00% 2. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 9 years 4. No public records

Waived

Compliance

EG2

9/20/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537581

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception due to loan amount is $XXXX vs program minimum of $150,000.00Compensating Factors:1. 27.00% DTI, 23% less than program guideline maximum DTI of 50.00%2. 66 months , 61 months greater than program guideline 5 months reserves requirement3. Owner of the same business for 20 years4. No public records5. Excellent mortgage payment history since 02/1994

7000-2513

8/9/2019

Waived/Exception Granted

08/09/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 27.00% DTI, 23% less than program guideline maximum DTI of 50.00% 2. 66 months , 61 months greater than program guideline 5 months reserves requirement 3. Owner of the same business for 20 years 4. No public records 5. Excellent mortgage payment history since 02/1994

Waived

Credit

EG2

8/8/2019

Primary Residence

TX

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430537581

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing copy of Hazard Insurance policy for property located at XXXX. Subject to recalculation of debt ratios.

7000-2535

8/28/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 27.00% DTI, 23% less than program guideline maximum DTI of 50.00% 2. 66 months , 61 months greater than program guideline 5 months reserves requirement 3. Owner of the same business for 20 years 4. No public records 5. Excellent mortgage payment history since 02/1994

Cured

Credit

EG1

8/8/2019

Primary Residence

TX

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430537582

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Allow both borrowers' to be treated as US Citizens vs program guideline that both borrowers' have USCIA issued EAD category CO8 Asylum applicants.Compensating Factors: 1. 722 FICO, 42 points greater than program guideline minimum FICO of 6802. 26 months reserves, 23 months greater than program guideline 3 months requirement 3. Owner of the same business for 3 years

7000-2114

6/28/2019

Waived/Exception Granted

Seller opted to waive requirement.

Compensating Factors: 1. 722 FICO, 42 points greater than program guideline minimum FICO of 680 2. 26 months reserves, 23 months greater than program guideline 3 months requirement 3. Owner of the same business for 3 years

Waived

Credit

EG2

6/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537582

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: DTI is 44.30% vs program guideline maximum DTI of 43.00%Compensating Factors: 1. 722 FICO, 42 points greater than program guideline minimum FICO of 6802. 26 months reserves, 23 months greater than program guideline 3 months requirement 3. Owner of the same business for 3 years

7000-2112

6/28/2019

Waived/Exception Granted

Seller opted to waive requirement.

Compensating Factors: 1. 722 FICO, 42 points greater than program guideline minimum FICO of 680 2. 26 months reserves, 23 months greater than program guideline 3 months requirement 3. Owner of the same business for 3 years

Waived

Credit

EG2

6/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537582

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

There is a Warranty Deed in file, however, it is incomplete.  Need fully executed Deed, inclusive of all dates and signatures.

7000-2101

7/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

7/2/19: Received fully executed and notarized Warranty Deed.

Compensating Factors: 1. 722 FICO, 42 points greater than program guideline minimum FICO of 680 2. 26 months reserves, 23 months greater than program guideline 3 months requirement 3. Owner of the same business for 3 years

Cured

Compliance

EG1

6/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537583

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client Approved Exception: Borrower has been self employed for two years which started in XXXX with XXX, Inc. Borrower created a new company XXX Inc. On XXX (10 months). Allow 10 months of bank statements from new company XXXX Inc. combined with two months of statements from XXXX. Compensating Factors:1. 32.60% DTI, 17.40% less than program guideline maximum DTI of 50.00%2. 28 months reserves, 25 months greater than program guideline 3 month reserves requirement3. 682 FICO score, 22 points greater than program guideline minimum FICO of 6604. Excellent mortgage payment history since inception on 03/2011 for first report mortgage on credit report 5. No public records

7000-2734

8/21/2019

Waived/Exception Granted

Compensating Factors: 1. 32.60% DTI, 17.40% less than program guideline maximum DTI of 50.00% 2. 28 months reserves, 25 months greater than program guideline 3 month reserves requirement 3. 682 FICO score, 22 points greater than program guideline minimum FICO of 660 4. Excellent mortgage payment history since inception on 03/2011 for first report mortgage on credit report 5. No public records

Waived

Credit

EG2

8/21/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537583

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  On the revised Loan Estimate (LE) in file dated XXXX the "Broker Fee" increased by $1,210.00 and the "Transfer Taxes" increased by $192.00, both without a valid Change of Circumstance, resulting in the below TRID Tolerance Violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $1,402.00.

7000-2721

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/22/2019: Received 06/10/2019 COC.

Compensating Factors: 1. 32.60% DTI, 17.40% less than program guideline maximum DTI of 50.00% 2. 28 months reserves, 25 months greater than program guideline 3 month reserves requirement 3. 682 FICO score, 22 points greater than program guideline minimum FICO of 660 4. Excellent mortgage payment history since inception on 03/2011 for first report mortgage on credit report 5. No public records

Cured

Compliance

EG1

8/21/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537584

XXXX

XXXX

XXXX

Credit - Credit

Missing updated Client approved exception. Exception approval was completed for the following: Borrower completing a short sale within 48 months of the date of the loan. However, the terms of the loan in the exception do not match the terms of the closed loan file. Exception loan amount shows $390,245.00 versus actual loan amount of $XXX.00 Compensating factors 1. 696 FICO is 36 points greater than the minimum of 660 required by the lender guidelines 2. Rental housing history is 0x30 for 24 months3. Borrower is the XXXX at XXXX for past 2 years4. Co-Borrower is an XXX with XXX for the past 2 years5. Subject is new construction

7000-2815

9/4/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating factors 1. 696 FICO is 36 points greater than the minimum of 660 required by the lender guidelines 2. Rental housing history is 0x30 for 24 months 3. Borrower is the xxxx at xxxx for past 2 years 4. Co-Borrower is an xxxx with xxxx for the past 2 years 5. Subject is new construction

Waived

Credit

EG2

8/27/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537584

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  Closing Disclosure in file dated XXX is missing the Seller paid fees according to the Seller's CD in file dated XXXX.  Need Post Consummation CD with letter to borrower and proof of method of delivery to borrower reflecting all Seller paid fees.

7000-2808

9/3/2019

Waived/Exception Granted

Compensating factors 1. 696 FICO is 36 points greater than the minimum of 660 required by the lender guidelines 2. Rental housing history is 0x30 for 24 months 3. Borrower is the xxxx at xxxx for past 2 years 4. Co-Borrower is an xxxx with xxxx for the past 2 years 5. Subject is new construction

Waived

Compliance

EG2

8/27/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537585

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2640

8/20/2019

Waived/Exception Granted

Compensating Factors: 1. 28.99% DTI, 21.01% less than program guideline maximum DTI of 50.00% 2. Owner of the same business for 10 years 3. 747 FICO, 87 points greater than program guideline minimum FICO of 660 4. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement

Waived

Compliance

EG2

8/19/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537585

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  NJ Mortgage Broker Agreement.

7000-2648

8/20/2019

Waived/Exception Granted

Compensating Factors: 1. 28.99% DTI, 21.01% less than program guideline maximum DTI of 50.00% 2. Owner of the same business for 10 years 3. 747 FICO, 87 points greater than program guideline minimum FICO of 660 4. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement

Waived

Compliance

EG2

8/19/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537585

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  In CD issued XXXX, it is incomplete as it is missing page 4 in its entirety. Unable to validate all TRID compliance items. Need entire copy of XXX CD with page 4 included.

7000-2644

8/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/20/2019: Received all pages of 08/08/2019 final CD - data in Contacts and Calculations section was complete and correct.

Compensating Factors: 1. 28.99% DTI, 21.01% less than program guideline maximum DTI of 50.00% 2. Owner of the same business for 10 years 3. 747 FICO, 87 points greater than program guideline minimum FICO of 660 4. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement

Cured

Compliance

EG1

8/19/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537585

XXXX

XXXX

XXXX

Credit - Credit

Missing satisfactory mortgage rating 1x30 for past 7 months from 07/2018 through 03/2019 for rental property located at XXXX with XXXX account ending in xxxx Compensating Factors:1. 28.99% DTI, 21.01% less than program guideline maximum DTI of 50.00%2. Owner of the same business for 10 years3. 747 FICO, 87 points greater than program guideline minimum FICO of 6604. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement

7000-2696

9/23/2019

Waived/Exception Granted

Client elected to waive exception with compensating factors

Compensating Factors: 1. 28.99% DTI, 21.01% less than program guideline maximum DTI of 50.00% 2. Owner of the same business for 10 years 3. 747 FICO, 87 points greater than program guideline minimum FICO of 660 4. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement

Waived

Credit

EG2

8/19/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537587

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing verification of self employment for a minimum of 2 continuous years as a XXX using Business License, CPA Letter or Regulatory Agency. \\\Update 8/13/2019  There is no documentation to evidence the borrower has been continuously self-employed for 2 years as a health care provider. The LOE provided reflects that the borrower took time off from this position to address personal matters.Compensating Factors:1. 801 credit score; 161 points greater than 640 program requirement2. borrower has been self-employed for the past 12 years as a XXX with XXXX. Perfect credit history since inception of earliest account opened 2/19984. No Public Records

7000-2410

9/4/2019

Waived/Exception Granted

Compensating Factors: 1. 801 credit score; 161 points greater than 640 program requirement 2. borrower has been self-employed for the past 12 years as a xxxx with xxxx 3. Perfect credit history since inception of earliest account opened 2/1998 4. No Public Records

Waived

Credit

EG2

7/24/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537587

XXXX

XXXX

XXXX

Credit - Income and Assets

Debt to income ratio of 54.56% exceeds maximum allowed. The November 2018 bank statement from XXX account ending in xxxx reflected a transfer of $1,000.00 that was not backed out of the borrower's income calculation. Additionally, the borrower was qualified paying off 2 revolving accounts at closing. Settlement statement reflected only 1 of 2 revolving accounts were paid in full. //UPDATED 07/30 - Received verification additional revolving debt was paid prior to closing. Revised DTI is 53.45%. Exception form allows for max 52.50% DTI.Compensating Factors:1. 801 credit score; 161 points greater than 640 program requirement2. borrower has been self-employed for the past 12 years as a XXX with XXX. Perfect credit history since inception of earliest account opened 2/19984. No Public Records

7000-2412

9/4/2019

Waived/Exception Granted

Compensating Factors: 1. 801 credit score; 161 points greater than 640 program requirement 2. borrower has been self-employed for the past 12 years as a xxxx with xxxx 3. Perfect credit history since inception of earliest account opened 2/1998 4. No Public Records

Waived

Credit

EG2

7/24/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537587

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing evidence XXXX account ending in xxxx with a monthly payment of $28.00  was paid at closing. Debt to income ratio is subject to recalculation.

7000-2414

7/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

7/30/19: Received letter from xxxx verifying account had zero balance as of 07/15/2019.

Compensating Factors: 1. 801 credit score; 161 points greater than 640 program requirement 2. borrower has been self-employed for the past 12 years as a xxxx with xxxx 3. Perfect credit history since inception of earliest account opened 2/1998 4. No Public Records

Cured

Credit

EG1

7/24/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537587

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure (CD) in file dated XXX is missing all of the Seller Paid fees according to the Final Combined Closing Statement in file dated XXXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-2403

7/29/2019

Waived/Exception Granted

Compensating Factors: 1. 801 credit score; 161 points greater than 640 program requirement 2. borrower has been self-employed for the past 12 years as a xxxx with xxxx 3. Perfect credit history since inception of earliest account opened 2/1998 4. No Public Records

Waived

Compliance

EG2

7/24/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537588

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Closing Disclosure in file dated XXXX is Missing All of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.   Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2406

7/29/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 07/29/2019: Received PCCD with borrower letter and proof of delivery, reflecting seller-paid fees.

Compensating Factors: 1. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement 2. 13.843% lower than program guideline maximum DTI of 43.00% 3. Owner of the same business for 4 years

Cured

Compliance

EG2

7/24/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537588

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure and TX Mortgage Company Disclosure.

7000-2407

7/29/2019

Waived/Exception Granted

Compensating Factors: 1. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement 2. 13.843% lower than program guideline maximum DTI of 43.00% 3. Owner of the same business for 4 years

Waived

Compliance

EG2

7/24/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537588

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 08/01/2019: The appraisal report was received and now reflects XXX County.  However, page 2 of the Deed of Trust still reflects XXXX County. Need Lender's Attestation with evidence Deed of Trust recorded in XXXX County. The Deed of Trust dated XXXX on Page 2 of 16  reflects property in XXXX County, however, the Legal  Description on Page 11 reflects the property is in XXXX County.  The Appraisal in file shows on page 1,  that property is in XXXX County, however on page 27,  the Tax sheet reflects the property is in XXXX County.  The Tax Record Information sheet reflects XXXX County as well as USPS Zip code Directory.  Need Lender's Attestation regarding the error and corrections to Deed of Trust and Appraisal.  Need explanation letter to borrower and proof of method of delivery.

7000-2404

8/2/2019

Property condition cleared

Received notice of correction changing the recorded DOT to xxxx county from xxxx County.

Compensating Factors: 1. 21 months reserves, 18 months greater than program guideline 3 months reserves requirement 2. 13.843% lower than program guideline maximum DTI of 43.00% 3. Owner of the same business for 4 years

Cured

Compliance

EG1

7/24/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537589

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Appraisal Fee increased on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $25.00.

7000-2804

9/3/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 09/03/2019: Received PCCD, borrower letter, reimbursement check, and proof of delivery.

Compensating Factors: 1. 771 credit score; 51 points above minimum credit score of 720 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 7.25 years 4. DTI ratio of 39.91%; 10.09% less than 50% maximum

Cured

Compliance

EG2

8/28/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537589

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 09/03/2019: Received PCCD with borrower letter and proof of delivery, reflecting seller-paid fees. However, the total seller-paid fees do not match the seller-paid fees as listed on the XXXX Alta Settlement Statement - variance due to $375.00 Title - Settlement Fee. Need Post Consummation Closing Disclosure with borrower letter and proof of delivery, or Client may choose to waive. The Closing Disclosure dated XXXX is Missing almost all of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2802

9/4/2019

Waived/Exception Granted

Compensating Factors: 1. 771 credit score; 51 points above minimum credit score of 720 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 7.25 years 4. DTI ratio of 39.91%; 10.09% less than 50% maximum

Waived

Compliance

EG2

8/28/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537591

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

UPDATE 08/01/2019: Received Signature/Name Affidavit for XXXX, which was already in file and does not reflect the name variation "XXXX" per the Warranty Deed and co-borrower identification. Need new Signature/Name Affidavit to include name variation "XXXX."  Document not properly executed or dated: The security instrument is vested, and the loan documents were drawn with the co-borrower's first name listed as "XXXX." However, the Warranty Deed transferred ownership with co-borrower's first name listed as "XXXX." The co-borrower's identification showed her name as "XXXX", yet the Notary acknowledged the co-borrower as "XXXX" per notary jurat. Finally, the signed Closing Instructions showed the co-borrower's name was to be listed as "XXXX" in the legal vesting, when the Closing Protection Letter references the co-borrower's name as "XXXX".

7000-2442

8/21/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATED 08/21/2019: Received updated AKA/Name Affidavit, which included name variation xxxx.

Compensating Factors: 1. 85.00% LTV; 5.00% below 90.00% maximum 2. DTI of 38.40%, 11.60% lower than the max DTI of 50.00% as required in the guidelines 3. 18 months reserves; 14 months greater than 4 months reserves required 4. 714 credit score; 54 points above minimum credit score of 660 as required by guidelines

Cured

Compliance

EG2

7/30/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537591

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

UPDATE 08/01/2019: Received Signature/Name Affidavit for XXXX, which was already in file and does not reflect the name variation "XXXX" per the Warranty Deed and co-borrower identification. Need new Signature/Name Affidavit to include name variation "XXXX."  Document not properly executed or dated: The Signature Affidavit showed the co-borrower's name was notarized with first name as "XXXX" when the co-borrower's identification showed her first name listed as "XXXX."

7000-2443

8/21/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/21/2019: Received updated AKA/Name Affidavit, which included name variation xxxx.

Compensating Factors: 1. 85.00% LTV; 5.00% below 90.00% maximum 2. DTI of 38.40%, 11.60% lower than the max DTI of 50.00% as required in the guidelines 3. 18 months reserves; 14 months greater than 4 months reserves required 4. 714 credit score; 54 points above minimum credit score of 660 as required by guidelines

Cured

Compliance

EG2

7/30/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537591

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing signed letter of explanation and source of the following large deposits into Co-borrower's XXXX account ending xxxxxx: $xx,xxx on 07/01/2019. Subject to recalculation of assets.

7000-2457

8/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

8/1/19: Deposit is $20K gift plus $16K business check.

Compensating Factors: 1. 85.00% LTV; 5.00% below 90.00% maximum 2. DTI of 38.40%, 11.60% lower than the max DTI of 50.00% as required in the guidelines 3. 18 months reserves; 14 months greater than 4 months reserves required 4. 714 credit score; 54 points above minimum credit score of 660 as required by guidelines

Cured

Credit

EG1

7/30/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537591

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing transfer evidence of Earnest Money Deposit in the amount of $xx,xxxx to the closing agent or borrower prior to closing. Subject to recalculation of assets.

7000-2458

8/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

8/1/19: Check is part of $36K deposit on 7/1/2019 into xxxx account ending xxxx. $20K gift plus $16K business check.

Compensating Factors: 1. 85.00% LTV; 5.00% below 90.00% maximum 2. DTI of 38.40%, 11.60% lower than the max DTI of 50.00% as required in the guidelines 3. 18 months reserves; 14 months greater than 4 months reserves required 4. 714 credit score; 54 points above minimum credit score of 660 as required by guidelines

Cured

Credit

EG1

7/30/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537592

XXXX

XXXX

XXXX

Credit - Credit

Missing credit report from loan file. Unable to determine amount of total liabilities, final debt to income ratio, fico scores and number of trade lines

7000-2441

7/31/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Rcvd Credit Report

Compensating Factors: 1. DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines 2. 7 months reserves; 4 months greater than 3 months reserves required

Cured

Credit

EG1

7/31/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537592

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception due to Borrower has been self-employed for the past 22 months vs program requirement 24 months self-employment historyCompensating Factors:1.DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines2.7 months reserves; 4 months greater than 3 months reserves required

7000-2444

7/29/2019

Waived/Exception Granted

07/29/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines 2. 7 months reserves; 4 months greater than 3 months reserves required

Waived

Credit

EG2

7/31/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537592

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception to allow VA appraisal with Completion Inspection vs program requirement to obtain a 1004D when the appraisal is made "subject to"Compensating Factors:1.DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines2.7 months reserves; 4 months greater than 3 months reserves required

7000-2445

7/29/2019

Waived/Exception Granted

07/29/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines 2. 7 months reserves; 4 months greater than 3 months reserves required

Waived

Credit

EG2

7/31/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537592

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception due to subject is a Non-Arms Length transaction with 1 appraisal (not listed on MLS and parents own home next door per appraiser) vs program requirement of 2 appraisals for Non Arm Length transactionCompensating Factors:1.DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines2.7 months reserves; 4 months greater than 3 months reserves required

7000-2446

7/29/2019

Waived/Exception Granted

07/29/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines 2. 7 months reserves; 4 months greater than 3 months reserves required

Waived

Credit

EG2

7/31/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537592

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception due to water was not on at time of inspection vs program requirement to confirm all utilities are in working order.Compensating Factors:1.DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines2.7 months reserves; 4 months greater than 3 months reserves required

7000-2447

7/29/2019

Waived/Exception Granted

07/29/2019: Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines 2. 7 months reserves; 4 months greater than 3 months reserves required

Waived

Credit

EG2

7/31/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537592

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2448

7/30/2019

Waived/Exception Granted

Compensating Factors: 1. DTI of 14.49%, 35.51% lower than the max DTI of 50.00% as required in the guidelines 2. 7 months reserves; 4 months greater than 3 months reserves required

Waived

Compliance

EG2

7/31/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537593

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing signed Lender's explanation for incomplete Closing Disclosure in file, as it is not marked as "Draft" or "Preliminary".

7000-2982

9/13/2019

Waived/Exception Granted

Compensating Factors: 1. Owner of the same business for the past 16 years 2. 769 FICO Scores, 49 points greater than the program guideline minimum FICO of 720 3. 41.09% DTI, 8.91% less than program guideline maximum DTI of 50.00% 4. 12 months reserves, 7 months greater than program guideline 5 months reserves requirement

Waived

Compliance

EG2

9/13/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430537593

XXXX

XXXX

XXXX

Property - Collateral

Per appraisal, "The improvement has been modified to function as a SFR w/Accessory unit; no permits were pulled per the XXXX County permits division".  This is considered a health and safety issue as the Accessory unit may not be up to local code.  Since the unit is given value within the appraisal a permit to determine the safety of the unit is recommended.

7000-2994

9/17/2019

Property condition cleared

Addendum  was provided

Compensating Factors: 1. Owner of the same business for the past 16 years 2. 769 FICO Scores, 49 points greater than the program guideline minimum FICO of 720 3. 41.09% DTI, 8.91% less than program guideline maximum DTI of 50.00% 4. 12 months reserves, 7 months greater than program guideline 5 months reserves requirement

Cured

Property

EG1

9/13/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430537593

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Allow down payment and closing costs paid with borrowers business funds vs program requirement that business funds used for down payment and/or closing costs must be transferred to borrowers personal accountCompensating Factors:1. Owner of the same business for the past 16 years2. 769 FICO Scores, 49 points greater than the program guideline minimum FICO of 7203. 41.09% DTI, 8.91% less than program guideline maximum DTI of 50.00%4. 12 months reserves, 7 months greater than program guideline 5 months reserves requirement

7000-3011

9/13/2019

Waived/Exception Granted

Compensating Factors: 1. Owner of the same business for the past 16 years 2. 769 FICO Scores, 49 points greater than the program guideline minimum FICO of 720 3. 41.09% DTI, 8.91% less than program guideline maximum DTI of 50.00% 4. 12 months reserves, 7 months greater than program guideline 5 months reserves requirement

Waived

Credit

EG2

9/13/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430537593

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing XXX Banks 08/2018 statement account ending in xxxx. Loan is subject to income recalculation

7000-3014

9/17/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. Owner of the same business for the past 16 years 2. 769 FICO Scores, 49 points greater than the program guideline minimum FICO of 720 3. 41.09% DTI, 8.91% less than program guideline maximum DTI of 50.00% 4. 12 months reserves, 7 months greater than program guideline 5 months reserves requirement

Cured

Credit

EG1

9/13/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430537596

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2625

8/19/2019

Waived/Exception Granted

Compensating Factors: 1. 690 credit score; 10 points above minimum credit score of 680 as required by guidelines 2. 53.333% LTV; 31.667% below 85% maximum 3. No public records 4. Borrower has been employed for the last 10.5 years 5. DTI ratio of 46.46%; 3.54% less than 50% maximum

Waived

Compliance

EG2

8/16/2019

Primary Residence

GA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537596

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Disclosure.

7000-2628

8/19/2019

Waived/Exception Granted

Compensating Factors: 1. 690 credit score; 10 points above minimum credit score of 680 as required by guidelines 2. 53.333% LTV; 31.667% below 85% maximum 3. No public records 4. Borrower has been employed for the last 10.5 years 5. DTI ratio of 46.46%; 3.54% less than 50% maximum

Waived

Compliance

EG2

8/16/2019

Primary Residence

GA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537602

XXXX

XXXX

XXXX

Credit - Credit

Missing explanation regarding the partial rent payments for the months of 9/2018, 12/2018, 2/2019 and 6/2019.  VOR shows monthly payment of $1200.00, however noted months reflect payment to landlord of $1,080 (9/18), $1190 (12/2018), $1,050 (2/2019) and $1110 (6/2019).

7000-2706

8/21/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. Owner of the same business for 11 years 2. 702 FICO score, 22 points greater than program guideline minimum FICO of 680 3. 36.36% DTI, 6.64% less than program guideline maximum DTI of 43.00% 4. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

8/19/2019

Primary Residence

IN

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537602

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2650

8/22/2019

Waived/Exception Granted

Compensating Factors: 1. Owner of the same business for 11 years 2. 702 FICO score, 22 points greater than program guideline minimum FICO of 680 3. 36.36% DTI, 6.64% less than program guideline maximum DTI of 43.00% 4. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

8/19/2019

Primary Residence

IN

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537602

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Points increased on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $44.00.

7000-2651

8/22/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/22/2019: Received 07/10/2019 COC.

Compensating Factors: 1. Owner of the same business for 11 years 2. 702 FICO score, 22 points greater than program guideline minimum FICO of 680 3. 36.36% DTI, 6.64% less than program guideline maximum DTI of 43.00% 4. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG1

8/19/2019

Primary Residence

IN

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537607

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  Closing Disclosure in file dated XXX is missing the Seller paid fees according to the Seller's CD in file dated XXXX.  Need Post Consummation CD with letter to borrower and proof of method of delivery to borrower reflecting all Seller paid fees.

7000-3066

9/18/2019

Waived/Exception Granted

Compensating Factors 1. 714 FICO is 34 points greater than the minimum 680 required by the guidlelines 2.. 0x30 housing history for 12 months 3. Self-employed in same business for 2 years

Waived

Compliance

EG2

9/17/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537608

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.   The Closing Disclosure in file dated XXXX is Missing All of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2477

8/9/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/09/2019: Received Seller CD with PCCD, borrower letter, and proof of delivery, reflecting seller paid fees. The fees listed on the Seller CD and PCCD reconcile.

Compensating Factors: 1. 10.618% DTI, 32.382% less than program guideline maximum DTI of 43.00% 2. 16 months reserves, 13 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 3 years 4. No public records

Cured

Compliance

EG2

8/5/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537608

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-2478

8/7/2019

Waived/Exception Granted

Compensating Factors: 1. 10.618% DTI, 32.382% less than program guideline maximum DTI of 43.00% 2. 16 months reserves, 13 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 3 years 4. No public records

Waived

Compliance

EG2

8/5/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537608

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Licensing/Registration check returned the following results as of the application date of XXXX:  Loan Originator's NMLS #XXXX reflects Loan Originator is NOT Authorized to Represent Loan Originator Company NMLS #XXXX.

7000-2479

8/8/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

validated LO is showing license with lender. ALso shows authorized to conduct business. OK to clear

Compensating Factors: 1. 10.618% DTI, 32.382% less than program guideline maximum DTI of 43.00% 2. 16 months reserves, 13 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 3 years 4. No public records

Cured

Compliance

EG1

8/5/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537610

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 08/06/2019: Received Seller CD; however, the final Closing Disclosure dated XXXX is missing the seller fees. Need Post Consummation Closing Disclosure (PCCD) with letter to borrower and proof of method of delivery reflecting all seller-paid fees on the PCCD. Missing Seller's Closing Disclosure /Final Settlement Statement to confirm all Seller Paid Fees are reflected on the Post Consummation CD in file dated XXXX.  If fees not confirmed, will Need a Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2483

8/8/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/08/2019: Received PCCD with borrower letter, proof of delivery, and Seller CD - seller fees reconcile between Seller CD and PCCD.

Compensating Factors: 1. 49.045% LTV, 30.955% less than program guideline maximum LTV of 80.00% 2. 33 months reserves, 29 months greater than program guideline 4 months reserves requirement 3. Owner of the same business for 25 years 4. Excellent mortgage payment history 5. No public records

Cured

Compliance

EG2

8/5/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537610

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Closing Disclosure in file dated XXXX reflects Title - XXX Company for $695.00 listed in Section C and need to be moved to Section B per the Service Providers List.  Need Post Consummation Closing Disclosure, with borrower explanation letter and proof of delivery, reflecting the Title - Settlement Fee in Section B.

7000-2484

8/9/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/09/2019: Received PCCD with borrower letter and proof of delivery, showing $695.00 Settlement Fee only listed in Section B.

Compensating Factors: 1. 49.045% LTV, 30.955% less than program guideline maximum LTV of 80.00% 2. 33 months reserves, 29 months greater than program guideline 4 months reserves requirement 3. Owner of the same business for 25 years 4. Excellent mortgage payment history 5. No public records

Cured

Compliance

EG2

8/5/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537610

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing 12 months bank statements used to calculate the borrower's qualifying income of $xxx,xxx.xx. Subject to further review and conditions.

7000-2481

8/7/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/07/2019: Received 12 months bank statements to calculate income.

Compensating Factors: 1. 49.045% LTV, 30.955% less than program guideline maximum LTV of 80.00% 2. 33 months reserves, 29 months greater than program guideline 4 months reserves requirement 3. Owner of the same business for 25 years 4. Excellent mortgage payment history 5. No public records

Cured

Credit

EG1

8/5/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592943

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Borrower has only been on title and deed for the past 2.5 months (the subject property was in probate. Borrower took ownership of the subject as trustee of the estate on xx/xx/xxxx borrower must have been on title and deed for at least 90 days preceding the date of the new loanCompensating Factors:1. 34.68% DTI, 15.32% less than program guideline maximum DTI of 50.00%2. 108 months, 105 months greater than program guideline 3 months reserves requirement3. Employed with the same employer for the past 8 years4. No public records5. 635 FICO Score, 15 points greater than program guideline minimum FICO of 620

7000-2886

9/5/2019

Waived/Exception Granted

Compensating Factors: 1. 34.68% DTI, 15.32% less than program guideline maximum DTI of 50.00% 2. 108 months, 105 months greater than program guideline 3 months reserves requirement 3. Employed with the same employer for the past 8 years 4. No public records 5. 635 FICO Score, 15 points greater than program guideline minimum FICO of 620

Waived

Credit

EG2

9/4/2019

Primary Residence

MD

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430592943

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing required signed 4506-T\\\\Update 9/10/2019 4506 is not complete. The tax  years requested has not been completed.

7000-2887

9/17/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 34.68% DTI, 15.32% less than program guideline maximum DTI of 50.00% 2. 108 months, 105 months greater than program guideline 3 months reserves requirement 3. Employed with the same employer for the past 8 years 4. No public records 5. 635 FICO Score, 15 points greater than program guideline minimum FICO of 620

Cured

Credit

EG1

9/4/2019

Primary Residence

MD

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430537612

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender Credit was reduced on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($267.20) does not exceed or equal the comparable sum of specific and non-specific lendercredits ($272.00).   Total amount $4.80.

7000-2636

8/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/20/2019: Received 07/09/2019 COC reflecting reduction in loan amount per borrower request.

Compensating Factors: 1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines 2. 80% LTV; 5% below 85% maximum 3. Mortgage history is 0x30 for 12 months   4. No public records 5. DTI ratio of 41.11%; 8.89% less than 50% maximum

Cured

Compliance

EG1

8/17/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537612

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure and CO Civil Union Addendum to Uniform Residential Loan Application.  (applications state borrower is unmarried)

7000-2637

8/20/2019

Waived/Exception Granted

Compensating Factors: 1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines 2. 80% LTV; 5% below 85% maximum 3. Mortgage history is 0x30 for 12 months   4. No public records 5. DTI ratio of 41.11%; 8.89% less than 50% maximum

Waived

Compliance

EG2

8/17/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537612

XXXX

XXXX

XXXX

Credit - Income and Assets

Client approved exception to allow alimony income paid until 09/01/2021 to qualify when the program requirement of 3 years continuance when alimony income is used.Compensating Factors:1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines2. 80% LTV; 5% below 85% maximum3. Mortgage history is 0x30 for 12 months  4. No public records5. DTI ratio of 41.11%; 8.89% less than 50% maximum

7000-2683

8/17/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines 2. 80% LTV; 5% below 85% maximum 3. Mortgage history is 0x30 for 12 months   4. No public records 5. DTI ratio of 41.11%; 8.89% less than 50% maximum

Waived

Credit

EG2

8/17/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537612

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception to allow borrower to close with 6 months employment history when the program requirement of a minimum history of two years of employment income is recommended. Borrower was a homemaker and has never worked prior to current employment.Compensating Factors:1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines2. 80% LTV; 5% below 85% maximum3. Mortgage history is 0x30 for 12 months  4. No public records5. DTI ratio of 41.11%; 8.89% less than 50% maximum

7000-2684

8/17/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines 2. 80% LTV; 5% below 85% maximum 3. Mortgage history is 0x30 for 12 months   4. No public records 5. DTI ratio of 41.11%; 8.89% less than 50% maximum

Waived

Credit

EG2

8/17/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537612

XXXX

XXXX

XXXX

Credit - Income and Assets

The Minimum 3 months Reserve Requirement has/has not been met. Total verified assets $xx,xxx.xx less total funds into transaction $xx,xxx.xx = net reserves $x,xxx.xx versus PITIA $x,xxx.xx = 2.74 months reserves.   /// UPDATED 8/21/2019  The EMD was verified paid out of XXXX xxxxxx and considered part of the verified assets.  Verified assets and net reserves have not changed.   /// UPDATED 8/22/2019:  XXXX Stmt xxxxxx reflects balance of $x,xxx.xx and is less than original statement dated 5/31/18 of $x,xxx.xx.  Additional asset verification still needed.

7000-2701

8/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines 2. 80% LTV; 5% below 85% maximum 3. Mortgage history is 0x30 for 12 months   4. No public records 5. DTI ratio of 41.11%; 8.89% less than 50% maximum

Cured

Credit

EG1

8/17/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537612

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception for reserves in the file. Reserves of 2.09 month not meeting guideline requirement of 3 months. Compensating Factors:1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines2. 80% LTV; 5% below 85% maximum3. Mortgage history is 0x30 for 12 months  4. No public records5. DTI ratio of 41.11%; 8.89% less than 50% maximum

7000-2857

8/30/2019

Waived/Exception Granted

Compensating Factors: 1. 786 credit score; 146 points above minimum credit score of 640 as required by guidelines 2. 80% LTV; 5% below 85% maximum 3. Mortgage history is 0x30 for 12 months   4. No public records 5. DTI ratio of 41.11%; 8.89% less than 50% maximum

Waived

Credit

EG2

8/17/2019

Primary Residence

CO

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537614

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing source of the following large deposits into borrower's XXXX account ending xxxxxx: $40,000 on 06/20/2019. Subject to recalculation of assets.

7000-2551

8/16/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

8/16/19: Received xxxx statement sourcing $40K transfer.

Compensating Factors: 1. 754 credit score; 94 points above minimum credit score of 660 as required by guidelines 2. 57 months reserves; 54 months greater than 3 months reserve requirement 3. Housing history is 0x30 for 12 months

Cured

Credit

EG1

8/12/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537614

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing evidence as to who the XXXX account ending xxxxxx, belongs to. The online printouts in file do not reflect the name of the owner of the account. Subject to recalculation of assets.

7000-2548

8/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Condition cleared

Compensating Factors: 1. 754 credit score; 94 points above minimum credit score of 660 as required by guidelines 2. 57 months reserves; 54 months greater than 3 months reserve requirement 3. Housing history is 0x30 for 12 months

Cured

Credit

EG1

8/12/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537614

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure (CD) in file dated XXXX do not match the Seller Paid fees on the XXX Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-2518

8/15/2019

Waived/Exception Granted

Compensating Factors: 1. 754 credit score; 94 points above minimum credit score of 660 as required by guidelines 2. 57 months reserves; 54 months greater than 3 months reserve requirement 3. Housing history is 0x30 for 12 months

Waived

Compliance

EG2

8/12/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537614

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  On the revised Loan Estimate (LE) in file dated XXXX the "Lender Credits" decreased without a valid Change of Circumstance, resulting in the below TRID Tolerance Violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the lender credits that cannot decrease test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specific and non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits ($903.00).  The total tolerance violation is 903.00.This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $147.13, is not sufficient to reimburse the consumer the amount by which the tolerances were exceeded, $903.00.  The total tolerance violation is -$755.87.

7000-2519

8/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/13/2019: Received 07/19/2019 COC reflecting loan lock and terms match 07/23/2019 LE.

Compensating Factors: 1. 754 credit score; 94 points above minimum credit score of 660 as required by guidelines 2. 57 months reserves; 54 months greater than 3 months reserve requirement 3. Housing history is 0x30 for 12 months

Cured

Compliance

EG1

8/12/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537616

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2526

8/13/2019

Waived/Exception Granted

Compensating Factors: 1. 16.648% DTI, 33.352% less than program guideline maximum DTI of 50.00% 2. 533 months reserves, 530 months greater than program guideline 3 months reserves requirement 3. 783 FICO scores, 103 points greater than program guideline minimum FICO scores of 680 4. No public records 5. Excellent mortgage payment history

Waived

Compliance

EG2

8/9/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537616

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  IL Loan Brokerage Agreement and IL Loan Brokerage Disclosure Statement.

7000-2524

8/13/2019

Waived/Exception Granted

Compensating Factors: 1. 16.648% DTI, 33.352% less than program guideline maximum DTI of 50.00% 2. 533 months reserves, 530 months greater than program guideline 3 months reserves requirement 3. 783 FICO scores, 103 points greater than program guideline minimum FICO scores of 680 4. No public records 5. Excellent mortgage payment history

Waived

Compliance

EG2

8/9/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537618

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Grant Deed to confirm vesting.  Condition added upon post closing review.

7000-2510

8/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/13/2019: Received recorded Warranty Deed, transferring subject property into borrower's name - matches security instrument.

Compensating Factors: 1. 33.22% DTI, 16.78% less than program guideline maximum DTI of 50.00% 2. 12 months reserves, 9 months greater than program guideline 3 months reserves requirement 3. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00%

Cured

Compliance

EG1

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537618

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2504

8/13/2019

Waived/Exception Granted

Compensating Factors: 1. 33.22% DTI, 16.78% less than program guideline maximum DTI of 50.00% 2. 12 months reserves, 9 months greater than program guideline 3 months reserves requirement 3. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00%

Waived

Compliance

EG2

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537618

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-2505

8/13/2019

Waived/Exception Granted

Compensating Factors: 1. 33.22% DTI, 16.78% less than program guideline maximum DTI of 50.00% 2. 12 months reserves, 9 months greater than program guideline 3 months reserves requirement 3. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00%

Waived

Compliance

EG2

8/8/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537621

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing borrower-signed Signature Affidavit.

7000-2638

8/23/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/23/2019: Received AKA/Name Affidavit - Borrower dated 08/21/2019 - executed post close; borrower ID in file.

Compensating Factors: 1. 768 credit score; 48 points above minimum credit score of 720 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 3.17 years 4. DTI ratio of 4.31%; 38.69% less than 43% maximum

Cured

Compliance

EG2

8/15/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537621

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Grant Deed to confirm vesting.

7000-2615

8/16/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Received Grant Deed

Compensating Factors: 1. 768 credit score; 48 points above minimum credit score of 720 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 3.17 years 4. DTI ratio of 4.31%; 38.69% less than 43% maximum

Cured

Compliance

EG1

8/15/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537621

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Mortgage in file dated XXXX is missing Exhibit "A" as reflected on Page 2 of 8.  Need complete copy of Mortgage inclusive of all pages, including Exhibit A, signed and notarized.

7000-2616

8/21/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/21/2019: Received all pages of executed and notarized security instrument, including legal description.

Compensating Factors: 1. 768 credit score; 48 points above minimum credit score of 720 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 3.17 years 4. DTI ratio of 4.31%; 38.69% less than 43% maximum

Cured

Compliance

EG1

8/15/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537621

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2617

8/16/2019

Waived/Exception Granted

Compensating Factors: 1. 768 credit score; 48 points above minimum credit score of 720 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 3.17 years 4. DTI ratio of 4.31%; 38.69% less than 43% maximum

Waived

Compliance

EG2

8/15/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537621

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  NJ Mortgage Broker Agreement.

7000-2618

8/16/2019

Waived/Exception Granted

Compensating Factors: 1. 768 credit score; 48 points above minimum credit score of 720 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 3.17 years 4. DTI ratio of 4.31%; 38.69% less than 43% maximum

Waived

Compliance

EG2

8/15/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537626

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing the January 2019 bank statement for the borrower's account xxxxxx with XXXX Bank to support income used to qualify.

7000-2816

8/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating factos 1. FICO 677 is 17 points greater than the minimum of 660 required by the guidelines 2. No public records 3. 0x30 housing history for 22 months

Cured

Credit

EG1

8/28/2019

Primary Residence

TN

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537626

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure:  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the XXXX Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2833

8/29/2019

Waived/Exception Granted

Compensating factos 1. FICO 677 is 17 points greater than the minimum of 660 required by the guidelines 2. No public records 3. 0x30 housing history for 22 months

Waived

Compliance

EG2

8/28/2019

Primary Residence

TN

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537626

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing signed letter of explanation and source of all of the transfer credit deposits into the borrower's XXXX account dated 8/5/2019 ending in xxxxxx.  Statement does not show origination of the transfer credits. Subject to re-calculation of assets upon receipt.

7000-2825

9/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating factos 1. FICO 677 is 17 points greater than the minimum of 660 required by the guidelines 2. No public records 3. 0x30 housing history for 22 months

Cured

Credit

EG1

8/28/2019

Primary Residence

TN

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537626

XXXX

XXXX

XXXX

Credit - Legal Documentation

The Mortgage is missing the notary date and signature.

7000-2796

8/29/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/29/2019: Received all pages of the mortgage with riders.

Compensating factos 1. FICO 677 is 17 points greater than the minimum of 660 required by the guidelines 2. No public records 3. 0x30 housing history for 22 months

Cured

Credit

EG1

8/28/2019

Primary Residence

TN

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592946

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing appraisal invoice to confirm Appraisal Fee of $580.00 as reflected on Final Closing Disclosure dated XXXX.

7000-2474

8/9/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/09/2019: Received PCCD with borrower letter and proof of delivery, reflecting the correct POC appraisal fee amount.

Compensating Factors: 1. 732 credit score; 52 points above minimum credit score of 680 as required by guidelines 2. DTI of 35.42%, 7.58% lower than the max DTI of 43.00% as required in the guidelines 3. 15 months reserves; 9 months greater than 6 months reserve requirement 4. Borrower has been self-employed for the last 16 years 5. No public records

Cured

Compliance

EG2

8/2/2019

Primary Residence

LA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592946

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the XXXX Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees per XXXX Settlement Statement.

7000-2482

8/6/2019

Waived/Exception Granted

Compensating Factors: 1. 732 credit score; 52 points above minimum credit score of 680 as required by guidelines 2. DTI of 35.42%, 7.58% lower than the max DTI of 43.00% as required in the guidelines 3. 15 months reserves; 9 months greater than 6 months reserve requirement 4. Borrower has been self-employed for the last 16 years 5. No public records

Waived

Compliance

EG2

8/2/2019

Primary Residence

LA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592947

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Closing Disclosure dated XXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2517

8/14/2019

Waived/Exception Granted

Compensating Factors: 1. 28.57% DTI, 21.43% less than program guideline maximum DTI of 50.00% 2. 804 FICO scores, 124 points greater than program guideline minimum FICO scores of 680 3. 674 months reserves, 669 months greater than program guideline 5 months reserves requirement

Waived

Compliance

EG2

8/9/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592947

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Survey Fee increased on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $150.00.

7000-2520

8/15/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/15/2019: Received  PCCD, borrower letter, reimbursement check, and proof of delivery.

Compensating Factors: 1. 28.57% DTI, 21.43% less than program guideline maximum DTI of 50.00% 2. 804 FICO scores, 124 points greater than program guideline minimum FICO scores of 680 3. 674 months reserves, 669 months greater than program guideline 5 months reserves requirement

Cured

Compliance

EG2

8/9/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592947

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On CD issued XXXX, under the Estimated Taxes, Insurance and Assessments section on page one, This estimate includes, Other is missing a description of the other assessments that are not in escrow.  Need Post Consummation CD with a description of the other assessments that are not in escrow and explanation letter to borrower with proof of method of delivery of all to borrower.

7000-2511

8/15/2019

Waived/Exception Granted

Compensating Factors: 1. 28.57% DTI, 21.43% less than program guideline maximum DTI of 50.00% 2. 804 FICO scores, 124 points greater than program guideline minimum FICO scores of 680 3. 674 months reserves, 669 months greater than program guideline 5 months reserves requirement

Waived

Compliance

EG2

8/9/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592947

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On CD issued XXXX, under the Demand Feature section on page four, neither option is marked.  Need Post Consummation CD with one of the options marked under Demand Feature section on page four and explanation letter to borrower with proof of method of delivery of all to borrower.

7000-2512

8/15/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/15/2019: Received PCCD with borrower letter and proof of delivery, reflecting Demand Feature section completed.

Compensating Factors: 1. 28.57% DTI, 21.43% less than program guideline maximum DTI of 50.00% 2. 804 FICO scores, 124 points greater than program guideline minimum FICO scores of 680 3. 674 months reserves, 669 months greater than program guideline 5 months reserves requirement

Cured

Compliance

EG2

8/9/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592949

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Final Settlement Statement dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2764

8/26/2019

Waived/Exception Granted

Compensating Factors: 1. 27.98% DTI, 22.02% less than program guideline maximum DTI of 50.00% 2. 754 FICO scores, 74 points greater than program guideline minimum FICO of 680 3. Owner of the same business for 3 years and 9 months 4. No public records

Waived

Compliance

EG2

8/23/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592949

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Document not properly executed or dated:  The vesting on the General Warranty Deed does not match the Deed of Trust and no signed Closing Instructions were provided, to confirm how final vesting should read.

7000-2783

8/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 27.98% DTI, 22.02% less than program guideline maximum DTI of 50.00% 2. 754 FICO scores, 74 points greater than program guideline minimum FICO of 680 3. Owner of the same business for 3 years and 9 months 4. No public records

Cured

Compliance

EG1

8/23/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592949

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure and TX Mortgage Company Disclosure.

7000-2767

8/26/2019

Waived/Exception Granted

Compensating Factors: 1. 27.98% DTI, 22.02% less than program guideline maximum DTI of 50.00% 2. 754 FICO scores, 74 points greater than program guideline minimum FICO of 680 3. Owner of the same business for 3 years and 9 months 4. No public records

Waived

Compliance

EG2

8/23/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592950

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3171

10/2/2019

Waived/Exception Granted

Compensating Factors: 1. 652 credit score; 12 points above minimum credit score of 640 as required by guidelines 2. 60% LTV; 25% below 85% maximum 3. No public records 4. Borrower has been employed for the last 2 years 5. DTI ratio of 48.38%; 1.62% less than 50% maximum

Waived

Compliance

EG2

9/25/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592950

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance. Second Appraisal Fee added on Closing Disclosure XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation. Tolerance cure needed for $250.00. Lender to provide new PCCD along with proof of refund, letter of explanation and proof of receipt.

7000-3175

9/30/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

Lender provided $250 via 9/30/19 PCCD, along with copy of the check, LOE and POD

Compensating Factors: 1. 652 credit score; 12 points above minimum credit score of 640 as required by guidelines 2. 60% LTV; 25% below 85% maximum 3. No public records 4. Borrower has been employed for the last 2 years 5. DTI ratio of 48.38%; 1.62% less than 50% maximum

Cured

Compliance

EG2

9/25/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592950

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing appraisal invoice to confirm Appraisal Fee of $450.00 as reflected on Final Closing Disclosure dated XXXX.  Appraisal Invoice in file reflects $480.00.

7000-3176

10/2/2019

Waived/Exception Granted

Compensating Factors: 1. 652 credit score; 12 points above minimum credit score of 640 as required by guidelines 2. 60% LTV; 25% below 85% maximum 3. No public records 4. Borrower has been employed for the last 2 years 5. DTI ratio of 48.38%; 1.62% less than 50% maximum

Waived

Compliance

EG2

9/25/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592950

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Policy Exception Approval:  DTI is 51.94% versus program maximum of 50.00%Compensating factors:1. 60.00% LTV; 25.00% less than 85.00% program maximum2. 652 credit score; 12 points greater than 640 program minimum3. 11 months reserves; 4 months greater than 5 month program minimum (3 months + 2 months NOO property)4. Borrower has been employed for past 2 years as an XXXX with XXXX. One closed mortgage reflects paid as agreed6. No public records

7000-3192

10/2/2019

Waived/Exception Granted

client exception approval provided with compensating factors.

Compensating Factors: 1. 652 credit score; 12 points above minimum credit score of 640 as required by guidelines 2. 60% LTV; 25% below 85% maximum 3. No public records 4. Borrower has been employed for the last 2 years 5. DTI ratio of 48.38%; 1.62% less than 50% maximum

Waived

Credit

EG2

9/25/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537629

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance. Appraisal Fee, Document Preparation Fee and Misc Charges all increased on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX. This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $86.50.This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $69.00, is not sufficient to reimburse the consumer the amount by which the tolerances were exceeded, $86.50. After the $69.00 Lender Credit was applied, the remaining tolerance violation is $17.50.

7000-2774

9/3/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 09/03/2019: Received PCCD, borrower letter, reimbursement check, and proof of delivery.

Compensating Factors: 1. 23.75% DTI, 19.25% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 8 years 3. No public records

Cured

Compliance

EG2

8/26/2019

Primary Residence

OK

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537629

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the XXXX Settlement Statement in file dated Seller's Closing Disclosure in file dated XXXX. Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2795

9/6/2019

Waived/Exception Granted

Compensating Factors: 1. 23.75% DTI, 19.25% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 8 years 3. No public records

Waived

Compliance

EG2

8/26/2019

Primary Residence

OK

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537629

XXXX

XXXX

XXXX

Credit - Credit

Missing satisfactory mortgage rating 1x30 for past 12 months for the borrowers' departing residence located at XXXX

7000-2786

9/6/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 23.75% DTI, 19.25% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 8 years 3. No public records

Cured

Credit

EG1

8/26/2019

Primary Residence

OK

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537629

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Allow funds for down payment and closings costs coming from borrower's business account vs program requirement that if funds in a business bank or brokerage account have not been transferred to the borrowers personal accounts, such funds may not be included in down payment and closing fundsCompensating Factors:1. 23.75% DTI, 19.25% less than program guideline maximum DTI of 43.00%2. Owner of the same business for 8 years3. No public records

7000-2788

8/27/2019

Waived/Exception Granted

Compensating Factors: 1. 23.75% DTI, 19.25% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 8 years 3. No public records

Waived

Credit

EG2

8/26/2019

Primary Residence

OK

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537629

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Credit Score is 674 vs program requirement of 680Compensating Factors:1. 23.75% DTI, 19.25% less than program guideline maximum DTI of 43.00%2. Owner of the same business for 8 years3. No public records

7000-2789

8/27/2019

Waived/Exception Granted

Compensating Factors: 1. 23.75% DTI, 19.25% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 8 years 3. No public records

Waived

Credit

EG2

8/26/2019

Primary Residence

OK

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592951

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 09/19/2019: Received 08/07/2019 Change of Circumstance; however, COC is insufficient due to the following: The 08/07/2019 COC stated reason for change was loan was locked due to an interest rate-dependent charge. However, the XXXX and XXXX Loan Estimates showed that the loan was already locked prior to XXXX, and the lock expiration date noted on the XXXX Loan Estimate was the same lock expiration date as disclosed on the XXXX and XXXX Loan Estimates. The 08/07/2019 COC does not accurately address the reason for the COC as it relates to the XXXX LE changes. As a result, the loan still does not pass the TRID reimbursement amount test.This loan failed TRID zero fee tolerance.  Lender Credit decreased on 08/07/2019 without a valid Change of Circumstance results in the below TRID tolerance violation. This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits($1,321.00).This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $580.00, is not sufficient to reimburse the consumer the amount by which the tolerances were exceeded, $1,901.00. Need PCCD, along with cure check, LOE and POD reflecting the total cure amount of $1901.00 for increases in appraisal fees and origination charges without a valid change of circumstance.

7000-3075

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

received lock confirmation that support adjustment in pricing after initial lock

Compensating Factors: 1. 36.39% DTI, 6.61% less than program guideline maximum DTI of 43.00% 2. 739 FICO Scores, 59 points greater than program guideline minimum FICO scores of 680 3. Owner of the same business for 10 years 4. No public records

Cured

Compliance

EG1

9/17/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592951

XXXX

XXXX

XXXX

Property - Collateral

Missing required appraisal CDA for the lower value appraisal at $XXX on 08/05/2019.

7000-3055

9/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 36.39% DTI, 6.61% less than program guideline maximum DTI of 43.00% 2. 739 FICO Scores, 59 points greater than program guideline minimum FICO scores of 680 3. Owner of the same business for 10 years 4. No public records

Cured

Property

EG1

9/17/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592951

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Grant Deed to confirm vesting.

7000-3041

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

received Grant Deed and ownership ties out

Compensating Factors: 1. 36.39% DTI, 6.61% less than program guideline maximum DTI of 43.00% 2. 739 FICO Scores, 59 points greater than program guideline minimum FICO scores of 680 3. Owner of the same business for 10 years 4. No public records

Cured

Compliance

EG1

9/17/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592951

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3042

9/19/2019

Waived/Exception Granted

Compensating Factors: 1. 36.39% DTI, 6.61% less than program guideline maximum DTI of 43.00% 2. 739 FICO Scores, 59 points greater than program guideline minimum FICO scores of 680 3. Owner of the same business for 10 years 4. No public records

Waived

Compliance

EG2

9/17/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592951

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 09/19/2019: Received 08/07/2019 Change of Circumstance; however, COC is insufficient due to the following: The 08/07/2019 COC stated reason for change was loan was locked due to an interest rate-dependent charge. However, the XXX and XXX Loan Estimates showed that the loan was already locked prior to XXXX, and the lock expiration date noted on the XXXX Loan Estimate was the same lock expiration date as disclosed on the XXXX and XXXX Loan Estimates. The 08/07/2019 COC does not accurately address the reason for the COC as it relates to the XXXX LE changes. This loan failed TRID zero fee tolerance.  Lender Credit decreased on 08/07/2019 without a valid Change of Circumstance results in the below TRID tolerance violation. This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits($1,321.00).

7000-3045

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

received rate lock forms that disclose the adjustments in pricing after initial lock.

Compensating Factors: 1. 36.39% DTI, 6.61% less than program guideline maximum DTI of 43.00% 2. 739 FICO Scores, 59 points greater than program guideline minimum FICO scores of 680 3. Owner of the same business for 10 years 4. No public records

Cured

Compliance

EG1

9/17/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592951

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  NJ Mortgage Broker Agreement.

7000-3047

9/19/2019

Waived/Exception Granted

Compensating Factors: 1. 36.39% DTI, 6.61% less than program guideline maximum DTI of 43.00% 2. 739 FICO Scores, 59 points greater than program guideline minimum FICO scores of 680 3. Owner of the same business for 10 years 4. No public records

Waived

Compliance

EG2

9/17/2019

Primary Residence

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537630

XXXX

XXXX

XXXX

Credit - Insurance and Title

Missing title supplement reflecting the insured loan amount to match Note.

7000-3024

9/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors 1.767 FICO and is 127 points greater than the minimum of 640 required by the guidelines 2. 0x30 housing history for 12 months 3. No public records

Cured

Credit

EG1

9/12/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537630

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3021

9/17/2019

Waived/Exception Granted

Compensating Factors 1.767 FICO and is 127 points greater than the minimum of 640 required by the guidelines 2. 0x30 housing history for 12 months 3. No public records

Waived

Compliance

EG2

9/12/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537631

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2567

8/14/2019

Waived/Exception Granted

Compensating factors 1. FICO of 770 is 150 greater than the minimum of 620 required by the lender guidelines 2. No public records 3. 0x30 housing history for 12 months

Waived

Compliance

EG2

8/13/2019

Primary Residence

RI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537631

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing monthly tax obligation for the rental property located at XXXX. Subject to recalculation of debt to income ratio

7000-2585

8/15/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

8/15/19: Received county printout with proof of taxes.

Compensating factors 1. FICO of 770 is 150 greater than the minimum of 620 required by the lender guidelines 2. No public records 3. 0x30 housing history for 12 months

Cured

Credit

EG1

8/13/2019

Primary Residence

RI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537633

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 09/06/2019: Received XXXX PCCD, reflecting all title fees in Section C - no monetary cure required. However, still missing the borrower letter and proof of delivery of the aforementioned XXXX PCCD. This loan failed TRID zero fee tolerance.  Credit Report increased on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $12.16.

7000-2836

9/10/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 09/10/2019: Received PCCD with borrower letter and proof of delivery.

Compensating Factors: 1. 18 months reserves, 12 months greater than program guideline 6 months reserves requirement due to foreclosure with 48 months 2. 664 FICO Score, 24 points greater than program guideline minimum FICO of 640 3. 25.862% LTV, 49.138% less than program guideline maximum LTV of 75.00% 4. Subject property and investment properties both owned free and clear

Cured

Compliance

EG2

8/29/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537633

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: DTI is 50.858% vs program maximum DTI of 50.00%Compensating Factors:1. 18 months reserves, 12 months greater than program guideline 6 months reserves requirement due to foreclosure with 48 months2. 664 FICO Score, 24 points greater than program guideline minimum FICO of 6403. 25.862% LTV, 49.138% less than program guideline maximum LTV of 75.00%4. Subject property and investment properties both owned free and clear

7000-2839

8/29/2019

Waived/Exception Granted

Compensating Factors: 1. 18 months reserves, 12 months greater than program guideline 6 months reserves requirement due to foreclosure with 48 months 2. 664 FICO Score, 24 points greater than program guideline minimum FICO of 640 3. 25.862% LTV, 49.138% less than program guideline maximum LTV of 75.00% 4. Subject property and investment properties both owned free and clear

Waived

Credit

EG2

8/29/2019

Primary Residence

FL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592952

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2546

8/15/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/15/2019: Received PCCD with borrower letter and proof of delivery, reflecting seller-paid fees.

Compensating Factors: 1. 700 credit score; 20 points above minimum credit score of 680 as required by guidelines 2. 7 months reserves; 4 months greater than 3 months reserve requirement 3. DTI of 32.09%, 10.91% lower than the max DTI of 43.00% as required in the guidelines

Cured

Compliance

EG2

8/12/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592952

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Broker Fee changed from XXXX to Broker Fee Paid on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation. Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $6,300.00.This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $125.00, is notsufficient to reimburse the consumer the amount by which the tolerances were exceeded, $6,300.00.

7000-2549

8/15/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/15/2019: Received 07/29/2019 COC for pricing change to borrower-paid origination fee.

Compensating Factors: 1. 700 credit score; 20 points above minimum credit score of 680 as required by guidelines 2. 7 months reserves; 4 months greater than 3 months reserve requirement 3. DTI of 32.09%, 10.91% lower than the max DTI of 43.00% as required in the guidelines

Cured

Compliance

EG1

8/12/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592952

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  TX Mortgage Company Disclosure.

7000-2550

8/14/2019

Waived/Exception Granted

Compensating Factors: 1. 700 credit score; 20 points above minimum credit score of 680 as required by guidelines 2. 7 months reserves; 4 months greater than 3 months reserve requirement 3. DTI of 32.09%, 10.91% lower than the max DTI of 43.00% as required in the guidelines

Waived

Compliance

EG2

8/12/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592953

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing Required 4506-T

7000-3350

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

no tax returns used. W2 and paystubs only

Compensating Factors: 1. 797 credit score; 77 points above minimum credit score of 720 as required by guidelines 2. 68.75% LTV; 6.25% below 75% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been employed for the last 22 years 6. DTI ratio of 45.01%; 4.99% less than 50% maximum

Cured

Credit

EG1

10/2/2019

Primary Residence

CA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592953

XXXX

XXXX

XXXX

Property - Collateral

Loan approval is subject to satisfactory appraisal review.  Subject to further underwriting.  Additional conditions may apply.Missing required appraisal CDA.

7000-3340

10/7/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 797 credit score; 77 points above minimum credit score of 720 as required by guidelines 2. 68.75% LTV; 6.25% below 75% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been employed for the last 22 years 6. DTI ratio of 45.01%; 4.99% less than 50% maximum

Cured

Property

EG1

10/2/2019

Primary Residence

CA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592953

XXXX

XXXX

XXXX

Property - Collateral

Location map with subject and comparable is missing from the file.

7000-3341

10/7/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 797 credit score; 77 points above minimum credit score of 720 as required by guidelines 2. 68.75% LTV; 6.25% below 75% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been employed for the last 22 years 6. DTI ratio of 45.01%; 4.99% less than 50% maximum

Cured

Property

EG1

10/2/2019

Primary Residence

CA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592953

XXXX

XXXX

XXXX

Property - Collateral

Appraisal requires a sketch of the subject property.

7000-3342

10/7/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 797 credit score; 77 points above minimum credit score of 720 as required by guidelines 2. 68.75% LTV; 6.25% below 75% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been employed for the last 22 years 6. DTI ratio of 45.01%; 4.99% less than 50% maximum

Cured

Property

EG1

10/2/2019

Primary Residence

CA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592953

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 10/07/2019: Received PCCD with re-opened rescission, borrower letter, and proof of delivery. Condition will be cleared once confirmation obtained that the new rescission period ended without incident.This loan failed the TILA Right of Rescission test.  The funding date is before the third business day following consummation.  The rescission "midnight of" date was xx/xx/xxxx and according to CD dated XXXX the loan funded XXXX.  The Interest from and Disbursement dates are XXXX resulting in the below TILA Violation.  Need Post Consummation CD reflecting accurate Interest From and Disbursement dates with explanation letter to borrower and proof of method of delivery to borrower.

7000-3316

10/22/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/22/2019: Past 10/10/2019. Also received another PCCD with borrower letter, proof of delivery, and reimbursement for finance charge $50.00 per borrower cover letter. The 09/04/2019 $50.00 reimbursement for lender credit on final CD can be seen on the final Alta settlement statement and was alread applied to the transaction - applied to TRID zero fee violation (see EID# 3320).

Compensating Factors: 1. 797 credit score; 77 points above minimum credit score of 720 as required by guidelines 2. 68.75% LTV; 6.25% below 75% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been employed for the last 22 years 6. DTI ratio of 45.01%; 4.99% less than 50% maximum

Cured

Compliance

EG2

10/2/2019

Primary Residence

CA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592953

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance. Points increased on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $737.50.This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $50.00, is notsufficient to reimburse the consumer the amount by which the tolerances were exceeded, $737.50.

7000-3320

10/7/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 10/07/2019: Received 08/30/2019 COC.

Compensating Factors: 1. 797 credit score; 77 points above minimum credit score of 720 as required by guidelines 2. 68.75% LTV; 6.25% below 75% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been employed for the last 22 years 6. DTI ratio of 45.01%; 4.99% less than 50% maximum

Cured

Compliance

EG1

10/2/2019

Primary Residence

CA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430592953

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Added 10/07/2019: TILA Post-Consummation Revised Closing Disclosure Lending Policies This loan failed the TILA foreclosure rescission finance charge test. (12 CFR 1026.23(h), transferred from 12 CFR 226.23(h))The finance charge is $XXXX. The disclosed finance charge of $XXXX is not considered accurate for purposes of rescission because it is understated by more than $35.Resulting variance was $50.00. Added as a result of condition review of Conditions #3316 and #3320.

7000-3430

10/22/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/22/2019: Received PCCD with reimbursement check, borrower letter, and proof of delivery. NOTE: There is a $50.00 lender credit noted on the final Alta settlement statement dated xx/xx/xxxx. The reimbursement check was applied to the finance charge reimbursement per borrower letter.

Compensating Factors: 1. 797 credit score; 77 points above minimum credit score of 720 as required by guidelines 2. 68.75% LTV; 6.25% below 75% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been employed for the last 22 years 6. DTI ratio of 45.01%; 4.99% less than 50% maximum

Cured

Compliance

EG2

10/2/2019

Primary Residence

CA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: LTV is 82.00% vs program maximum of 80.00%Compensating Factors:1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties)2. 732 FICO, 72 points greater than program guideline minimum FICO of 6603. No public records

7000-2756

8/22/2019

Waived/Exception Granted

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Waived

Credit

EG2

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing verification of self employment for a minimum of 2 continuous years using Business License, CPA Letter or xxxx.

7000-2757

9/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Cured

Credit

EG1

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Mortgage Broker Fee increased on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $40.00.

7000-2746

8/26/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/26/2019: Received 7/25/2019 COC.

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Cured

Compliance

EG1

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender Credit was removed on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.This loan failed the lender credits that cannot decrease test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specific and non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits ($1,890.00). Please see the table that displays the Charges That Cannot Increase for a comparison of the data between the provided disclosures.  An estimated closing cost disclosed pursuant to 1026.19(e) is in good faith if the charge paid by or imposed on the consumer does not exceed the amount originally disclosed under 1026.19(e)(1)(i). This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $20.00, is not sufficient to reimburse the consumer the amount by which the tolerances were exceeded, $1,930.00.  Refunds related to the good faith analysis. If amounts paid by the consumer exceed the amounts specified under 1026.19(e)(3)(i) or (ii), the creditor complies with 1026.19(e)(1)(i) if the creditor refunds the excess to the consumer no later than 60 days after consummation, and the creditor complies with 1026.19(f)(1)(i) if the creditor delivers or places in the mail corrected disclosures that reflect such refund no later than 60 days after consummation.

7000-2747

8/26/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/26/2019: Received 7/26/2019 COC.

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Cured

Compliance

EG1

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  NV Disclosure of Fees Earned by Mortgage Broker.

7000-2748

8/26/2019

Waived/Exception Granted

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Waived

Compliance

EG2

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Lender over disclosed ETIA/Escrow collection on Final CD dated XXXX. Total ETIA and monthly escrow totals should be $463.61 not $759.62. Hazard Insurance premium of $1,192.00 monthly is $99.33.  For Taxes, used Tax Information Sheet, shows annual Property tax amount of $591.36  monthly $49.28. HOA monthly $315.00.  Adding these three monthly  amounts equals $463.61. NEED PCCD correcting escrows/ETIA, along with letter of explanation and proof of method of delivery to borrower.

7000-2750

9/13/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 09/13/2019: Received PCCD with borrower letter and proof of delivery.

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Cured

Compliance

EG2

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Credit - Credit

Missing a satisfactory mortgage or rent rating 1x30 for past 12 months is required for the primary borrower's XXXX. The primary borrower's indicates that he has owned a primary residence for 4 years; however, the DataVerify report and Credit Report indicates that the primary residence was purchase on xx/xx/xxxx

7000-2765

9/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Cured

Credit

EG1

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing July 2018 statement from XXXX account ending in xxxx. Guidelines required 12 month period preceding the month of the borrower's initial loan application. Loan is subject to income recalculation

7000-2769

9/13/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Cured

Credit

EG1

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Credit - Income and Assets

Recalculated income of $35,797.78 resulted in a DTI of 70.38% which exceeded loan program guideline maximum DTI of 50.00%. The schedule K1 in file indicate 50% ownership; however, the Lender calculated the income at 100% ownership // UPDATED 9/4/2019: Secretary of State Certificate of Limited Partnership does not overcome the verified 50% ownership percentage reflected on the 2017 K1 statement.  The K1 statement shows the same ownership percentage at the beginning and ending of 2017. \\\ Update 9/5/2019 Need 2017 K-1 to evidence that XXXX is a 50% owner in XXXX. The Cert of limited partnership does not reflect the ownership interest of XXXX in XXXX.

7000-2770

9/6/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Cured

Credit

EG1

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537641

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. XXXX, Inc. title fees listed in Section C should be listed in Section B as XXXX, Inc. was listed on the Written List of Service Providers. Need Post Consummation Closing Disclosure with borrower letter and proof of delivery, listing the aforementioned fees in Section B.

7000-2754

8/26/2019

Waived/Exception Granted

Compensating Factors: 1. 113 months reserves, 102 months greater than program guideline 11 months reserves requirement (3 for subject and 8 for rental properties) 2. 732 FICO, 72 points greater than program guideline minimum FICO of 660 3. No public records

Waived

Compliance

EG2

8/22/2019

Second Home

NV

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537642

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure, IL Loan Brokerage Agreement and IL Loan Brokerage Disclosure Statement.

7000-2854

9/3/2019

Waived/Exception Granted

Compensating factors: 1. 703 credit score; 23 points greater than 680 program requirement 2. 11.95 months reserves; 8.95 months greater than 3 month program requirement 3. One open mortgage reflects 0x30 since inception xx/xx/xx 4. Perfect credit history since inception of earliest account opened 7/10/2015 5. No public records

Waived

Compliance

EG2

8/30/2019

Primary Residence

IL

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537642

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Lender under disclosed ETIA/Escrow collection on Final CD dated XXXX. Total ETIA and monthly escrow totals should be $614.19 not $613.39. Hazard Insurance premium of $584.90 monthly is $48.74.  For Taxes, used Tax Information Sheet, shows semi-annual Property tax amount of $3,392.70  monthly $565.45.  Adding these monthly amounts equals $614.19. NEED PCCD correcting escrows/ETIA, along with letter of explanation and proof of delivery to borrower.

7000-2855

9/6/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 09/06/2019: Received PCCD with borrower letter and proof of delivery.

Compensating factors: 1. 703 credit score; 23 points greater than 680 program requirement 2. 11.95 months reserves; 8.95 months greater than 3 month program requirement 3. One open mortgage reflects 0x30 since inception xx/xx/xx 4. Perfect credit history since inception of earliest account opened 7/10/2015 5. No public records

Cured

Compliance

EG2

8/30/2019

Primary Residence

IL

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537642

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Subject property was listed for sale in the last 3 months. Listed for sale on xx/xx/xxx and removed on 07/2019 vs program requirement that the subject property has not been listed for sale, and may not have been listed for sale during the three-months period preceding the Date of the loanCompensating Factors:1. 703 credit score; 23 points greater than 680 program requirement2. 11 months reserves, 7 months greater than 3 month program requirement3. Borrower has been self-employed for the past 3 years4. One open mortgage reflects 0x30 since inception xxxx. Perfect credit history since inception of earliest account opened 7/10/20156. No public records

7000-2858

8/30/2019

Waived/Exception Granted

clients elects to waive exception with compensating factors.

Compensating factors: 1. 703 credit score; 23 points greater than 680 program requirement 2. 11.95 months reserves; 8.95 months greater than 3 month program requirement 3. One open mortgage reflects 0x30 since inception xx/xx/xx 4. Perfect credit history since inception of earliest account opened 7/10/2015 5. No public records

Waived

Credit

EG2

8/30/2019

Primary Residence

IL

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537642

XXXX

XXXX

XXXX

Credit - Income and Assets

The recalculated income of $x,xxx.xx. resulted in a DTI of 46.30%. The Lender calculated the borrower's using 90% of the CPA Verified Deposits vs the signed P&L by the CPA indicating 83.474% profit margin\\\\Update 9/19/2019 updated DTI and income figures.  Client exception for the DTI is located in the fileCompensating factors:1. 703 credit score; 23 points greater than 680 program requirement2. 11.95 months reserves; 8.95 months greater than 3 month program requirement3. One open mortgage reflects 0x30 since inception 12/28/164. Perfect credit history since inception of earliest account opened 7/10/20155. No public records

7000-2861

9/19/2019

Waived/Exception Granted

Compensating factors: 1. 703 credit score; 23 points greater than 680 program requirement 2. 11.95 months reserves; 8.95 months greater than 3 month program requirement 3. One open mortgage reflects 0x30 since inception xx/xx/xx 4. Perfect credit history since inception of earliest account opened 7/10/2015 5. No public records

Waived

Credit

EG2

8/30/2019

Primary Residence

IL

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537642

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception in the file for the DTI of 46.30% vs the program requirement of 43.00%. Compensating Factors:1. 703 credit score; 23 points greater than 680 program requirement2. 11 months reserves, 7 months greater than 3 month program requirement3. Borrower has been self-employed for the past 3 years4. One open mortgage reflects 0x30 since inception 12/28/20165. Perfect credit history since inception of earliest account opened 7/10/20156. No public records

7000-3085

9/19/2019

Waived/Exception Granted

Compensating factors: 1. 703 credit score; 23 points greater than 680 program requirement 2. 11.95 months reserves; 8.95 months greater than 3 month program requirement 3. One open mortgage reflects 0x30 since inception xx/xx/xx 4. Perfect credit history since inception of earliest account opened 7/10/2015 5. No public records

Waived

Credit

EG2

8/30/2019

Primary Residence

IL

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537644

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender Credit was removed on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits($2,794.00)

7000-2661

8/21/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/21/2019: Received 7/18/2019 COC reflecting relock at PAR/no lender credit.

Compensating Factors: 1. 121 months reserves, 118 months greater than program guideline 3 months reserves requirement 2. 74.874% LTV, 10.126% less than program guideline maximum LTV of 85.00% 3. 732 FICO, 12 points greater than program guideline minimum FICO of 720 4. 42.25% DTI, 7.75% less than program guideline maximum DTI of 50.00%

Cured

Compliance

EG1

8/19/2019

Second Home

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537644

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  NJ Attorney Fee Notice and NJ Mortgage Broker Agreement.

7000-2662

8/20/2019

Waived/Exception Granted

Compensating Factors: 1. 121 months reserves, 118 months greater than program guideline 3 months reserves requirement 2. 74.874% LTV, 10.126% less than program guideline maximum LTV of 85.00% 3. 732 FICO, 12 points greater than program guideline minimum FICO of 720 4. 42.25% DTI, 7.75% less than program guideline maximum DTI of 50.00%

Waived

Compliance

EG2

8/19/2019

Second Home

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537644

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2659

8/20/2019

Waived/Exception Granted

Compensating Factors: 1. 121 months reserves, 118 months greater than program guideline 3 months reserves requirement 2. 74.874% LTV, 10.126% less than program guideline maximum LTV of 85.00% 3. 732 FICO, 12 points greater than program guideline minimum FICO of 720 4. 42.25% DTI, 7.75% less than program guideline maximum DTI of 50.00%

Waived

Compliance

EG2

8/19/2019

Second Home

NJ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537646

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing signed Lender's explanation for incomplete Closing Disclosure in file, dated XXXX, as it is not marked as "Draft" or "Preliminary".

7000-2777

8/28/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/28/2019: Received Client Attestation.

Compensating Factors: 1. 13.279% DTI, 36.721% less than program guideline maximum DTI of 50.00% 2. 73 months reserves, 70 months greater than program guideline 3 months reserves requirement 3. 663 FICO Score, 23 points greater than program guideline minimum FICO of 640 4. No public records 5. Owner of the same business for 2 years

Cured

Compliance

EG2

8/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537646

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance. Mortgage Broker Fee was increased on Loan Estimate dated XXXX and on XXXX both without a Valid Change of Circumstance results in the below TRID tolerance violation. Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $68.00.

7000-2779

8/28/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/28/2019: Received 08/02/2019 COC.

Compensating Factors: 1. 13.279% DTI, 36.721% less than program guideline maximum DTI of 50.00% 2. 73 months reserves, 70 months greater than program guideline 3 months reserves requirement 3. 663 FICO Score, 23 points greater than program guideline minimum FICO of 640 4. No public records 5. Owner of the same business for 2 years

Cured

Compliance

EG1

8/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537646

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing signed LOE for source of  XXXX and XXXX deposits

7000-2803

8/29/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Conditions cleared as the deposits are new income and not transfers

Compensating Factors: 1. 13.279% DTI, 36.721% less than program guideline maximum DTI of 50.00% 2. 73 months reserves, 70 months greater than program guideline 3 months reserves requirement 3. 663 FICO Score, 23 points greater than program guideline minimum FICO of 640 4. No public records 5. Owner of the same business for 2 years

Cured

Credit

EG1

8/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537646

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. Closing Disclosure in file dated XXXX reflects title fees paid to XXXX, listed in Section C, when XXXX (xxxx, FL) was listed on the Service Provider's List and should be moved to Section B. Need Post Consummation Closing Disclosure with borrower letter and proof of delivery, reflecting all XXXX fees in Section B.

7000-2806

8/29/2019

Waived/Exception Granted

Compensating Factors: 1. 13.279% DTI, 36.721% less than program guideline maximum DTI of 50.00% 2. 73 months reserves, 70 months greater than program guideline 3 months reserves requirement 3. 663 FICO Score, 23 points greater than program guideline minimum FICO of 640 4. No public records 5. Owner of the same business for 2 years

Waived

Compliance

EG2

8/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537647

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing copy of current paystub for Borrower. No paystub in file. Subject to recalculation of income.

7000-2652

8/21/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 80.00% LTV; 10.00% below 90.00% maximum 2. 741 credit score; 61 points above minimum credit score of 680 as required by guidelines 3. DTI of 40.97%, 9.03% lower than the max DTI of 50.00% as required in the guidelines 4. 37 months reserves; 34 months greater than 3 months reserve requirement

Cured

Credit

EG1

8/16/2019

Investment Property

IN

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG1

EG2

EG2

EG3

EG1

10/30/2019

430537647

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing verification of self-employment for a minimum of 2 years using Business License, CPA Letter or Regulatory Agency. CPA letter states borrower has been client of firm since 2017; does not specify since when in 2017 borrower has been self-employed.

7000-2653

8/21/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 80.00% LTV; 10.00% below 90.00% maximum 2. 741 credit score; 61 points above minimum credit score of 680 as required by guidelines 3. DTI of 40.97%, 9.03% lower than the max DTI of 50.00% as required in the guidelines 4. 37 months reserves; 34 months greater than 3 months reserve requirement

Cured

Credit

EG1

8/16/2019

Investment Property

IN

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG1

EG2

EG2

EG3

EG1

10/30/2019

430537647

XXXX

XXXX

XXXX

Property - Collateral

Appraisal indicates , "smoke detectors are required by local building codes" and "were not noted at the time of inspection".  This is considered a health and safety issue. \\\ Update 9/5/2019 : The phots provided by the borrower are not sufficient to clear the condition. The appraisal addressed the issue of the missing smoke detectors and the appraisal must address that the issue with smoke detectors has been addressed and resolved.

7000-2656

9/6/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 80.00% LTV; 10.00% below 90.00% maximum 2. 741 credit score; 61 points above minimum credit score of 680 as required by guidelines 3. DTI of 40.97%, 9.03% lower than the max DTI of 50.00% as required in the guidelines 4. 37 months reserves; 34 months greater than 3 months reserve requirement

Cured

Property

EG1

8/16/2019

Investment Property

IN

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG1

EG2

EG2

EG3

EG1

10/30/2019

430537647

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Electronic Consent/ eSign Forms for both borrowers completed prior to earliest esign event.

7000-2606

8/19/2019

Waived/Exception Granted

Compensating Factors: 1. 80.00% LTV; 10.00% below 90.00% maximum 2. 741 credit score; 61 points above minimum credit score of 680 as required by guidelines 3. DTI of 40.97%, 9.03% lower than the max DTI of 50.00% as required in the guidelines 4. 37 months reserves; 34 months greater than 3 months reserve requirement

Waived

Compliance

EG2

8/16/2019

Investment Property

IN

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG1

EG2

EG2

EG3

EG1

10/30/2019

430592957

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing a verbal VOE within 10 business days prior to the Note Date for the co-borrower

7000-3056

10/14/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

workNumber VOE provided

Compensating Factors: 1. 747 FICO Scores, 107 points greater than program guideline minimum FICO Scores of 640 2. 16 months reserves, 13 months greater than program guideline 3 months reserves requirement 3. Primary borrower’s has been self employed with the same 2 businesses for the past 6 years 4. Co-borrower has been employed with the same employer for the past 13 years 5. No public records

Cured

Credit

EG1

9/17/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592957

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing documentation to evidence that the co-borrower works a full 40hrs work week. Loan is subject to income recalculation

7000-3057

9/23/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

used average base calculation

Compensating Factors: 1. 747 FICO Scores, 107 points greater than program guideline minimum FICO Scores of 640 2. 16 months reserves, 13 months greater than program guideline 3 months reserves requirement 3. Primary borrower’s has been self employed with the same 2 businesses for the past 6 years 4. Co-borrower has been employed with the same employer for the past 13 years 5. No public records

Cured

Credit

EG1

9/17/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592957

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Final Settlement Statement dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3037

9/19/2019

Waived/Exception Granted

Compensating Factors: 1. 747 FICO Scores, 107 points greater than program guideline minimum FICO Scores of 640 2. 16 months reserves, 13 months greater than program guideline 3 months reserves requirement 3. Primary borrower’s has been self employed with the same 2 businesses for the past 6 years 4. Co-borrower has been employed with the same employer for the past 13 years 5. No public records

Waived

Compliance

EG2

9/17/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537652

XXXX

XXXX

XXXX

Credit - Legal Documentation

The Deed of Trust in file is missing the legal description.  Deed of Trust in file reflects "SEE LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF AS "EXHIBIT A".", however, Exhibit A Legal Description is not attached.  Need full copy of Deed of Trust inclusive of Legal Description and all Riders. Updated 8/30/2019 The deed of trust provided by the client is dated XXXX and reflects a different lender and signed the guarantors of XXXX. The DOT does not pertain to the subject transaction and is not sufficient to meet the condition requirement.

7000-2665

9/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

rec'd recorded DOT

Compensating Factors: 1. 780 credit score; 60 points above minimum credit score of 720 as required by guidelines 2. Mortgage history is 0x30 for 12 months  3. No public records 4. Borrower has been self-employed for the last 6.92 years 5. DTI ratio of 2.055%; 47.945% less than 50% maximum

Cured

Credit

EG1

8/19/2019

Investment Property

CA

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG1

EG3

EG1

EG1

EG1

EG1

EG1

10/30/2019

430537652

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing copy of the Final Closing Disclosure for the subject property.

7000-2709

8/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 780 credit score; 60 points above minimum credit score of 720 as required by guidelines 2. Mortgage history is 0x30 for 12 months  3. No public records 4. Borrower has been self-employed for the last 6.92 years 5. DTI ratio of 2.055%; 47.945% less than 50% maximum

Cured

Credit

EG1

8/19/2019

Investment Property

CA

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG1

EG3

EG1

EG1

EG1

EG1

EG1

10/30/2019

430537653

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Mortgage in File dated XXXX is missing the Legal Description reflected as Exhibit A on page 2 of 10.  Need complete copy of Mortgage inclusive of all pages including Legal Description, signed and notarized.

7000-2610

8/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/20/2019: Received all pages of mortgage with legal description.

Compensating Factors: 1. 694 credit score; 14 points above minimum credit score of 680 as required by guidelines 2. Mortgage history is 0x30 for 12 months   3. No public records 4. Borrower has been self-employed for the last 5 years

Cured

Compliance

EG1

8/16/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537653

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing appraisal invoice to confirm Appraisal Fee of $425.00 as reflected on Final Closing Disclosure dated XXXX.

7000-2612

8/19/2019

Waived/Exception Granted

Compensating Factors: 1. 694 credit score; 14 points above minimum credit score of 680 as required by guidelines 2. Mortgage history is 0x30 for 12 months   3. No public records 4. Borrower has been self-employed for the last 5 years

Waived

Compliance

EG2

8/16/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537653

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID timing of disclosures.  Missing proof of consumer's receipt of Initial Closing Disclosure provided reflecting a Date Issued of XXXX and a Closing Date of XXXX results in the below TRID timing violation.  Initial Closing Disclosure Timing Requirements - XXXX This loan failed the initial closing disclosure delivery date test due to one of the following findings:(12 CFR 1026.19(f)(1)(ii))The initial closing disclosure delivery date is provided and the initial closing disclosure method of delivery is marked as either:"USPS First Class Mail" or "Electronic Delivery" or blank, and the initial closing disclosure delivery date is less than six business days (counting all calendar days except Sunday and specified legal public holidays) before the consummation date, or closing / settlement date if no consummation date is provided, of the transaction; or In Person" and the initial closing disclosure delivery date is less than three business days (counting all calendar days except Sunday and specified legal public holidays) before the consummation date, or closing / settlement date if no consummation date is provided, of the transaction; or The initial closing disclosure receipt date is provided and the initial closing disclosure receipt date is less than three business days (counting all calendar days except Sunday and specified legal public holidays) before the consummation date, or closing / settlement date if no consummation date is provided, of the transaction. The creditor shall ensure that the consumer receives the disclosures required under paragraph 1026.19(f)(1)(i) no later than three business days before consummation.

7000-2613

8/19/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 08/19/2019: Received 8/1/2019 Disclosure Tracking.

Compensating Factors: 1. 694 credit score; 14 points above minimum credit score of 680 as required by guidelines 2. Mortgage history is 0x30 for 12 months   3. No public records 4. Borrower has been self-employed for the last 5 years

Cured

Compliance

EG1

8/16/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537653

XXXX

XXXX

XXXX

Credit - Income and Assets

Client approved exception for DTI ratio of 45.46% is higher than the 43% maximum.Compensating Factors:1. 694 credit score; 14 points above minimum credit score of 680 as required by guidelines2. Mortgage history is 0x30 for 12 months  3. No public records4. Borrower has been self-employed for the last 5 years

7000-2664

8/16/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 694 credit score; 14 points above minimum credit score of 680 as required by guidelines 2. Mortgage history is 0x30 for 12 months   3. No public records 4. Borrower has been self-employed for the last 5 years

Waived

Credit

EG2

8/16/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537654

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing evidence of monthly obligations for taxes, hazard insurance and HOA dues (if applicable), for the property located at XXXX. Loan is subject to DTI recalculation

7000-2862

9/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1.27.78% DTI, 22.22% less than program guideline maximum DTI of 50.00% 2. 58.140% LTV, 31.86% less than program guideline maximum LTV of 90.00% 3. 778 FICO, 58 points greater than program guideline minimum FICO of 680 4. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement 5. Owner of the same business for 4 years

Cured

Credit

EG1

8/30/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537654

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2840

9/3/2019

Waived/Exception Granted

Compensating Factors: 1.27.78% DTI, 22.22% less than program guideline maximum DTI of 50.00% 2. 58.140% LTV, 31.86% less than program guideline maximum LTV of 90.00% 3. 778 FICO, 58 points greater than program guideline minimum FICO of 680 4. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement 5. Owner of the same business for 4 years

Waived

Compliance

EG2

8/30/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537654

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures: Loan Options Disclosure/Anti-Steering Options Disclosure and TX Mortgage Company Disclosure.

7000-2848

9/5/2019

Waived/Exception Granted

Compensating Factors: 1.27.78% DTI, 22.22% less than program guideline maximum DTI of 50.00% 2. 58.140% LTV, 31.86% less than program guideline maximum LTV of 90.00% 3. 778 FICO, 58 points greater than program guideline minimum FICO of 680 4. 11 months reserves, 8 months greater than program guideline 3 months reserves requirement 5. Owner of the same business for 4 years

Waived

Compliance

EG2

8/30/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537655

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-2654

8/20/2019

Waived/Exception Granted

Compensating Factors 1. 691 FICO is 11 points greater than the minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. 24.90% DTI; 18.10% lower than 43.00% program mazimum

Waived

Compliance

EG2

8/19/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537655

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2655

8/20/2019

Waived/Exception Granted

Compensating Factors 1. 691 FICO is 11 points greater than the minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. 24.90% DTI; 18.10% lower than 43.00% program mazimum

Waived

Compliance

EG2

8/19/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537655

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Lender underdisclosed ETIA/Escrow collection on Final CD dated XXXX. Total ETIA and monthly escrow totals should be $1054.47 not $1050.65. Hazard Insurance premium of $1,115.00 monthly is $92.92.  For Taxes, used Tax Information Sheet, shows annual Property tax amount of $2382.72  monthly $198.56, School Tax $8086.71 monthly $673.89, City Tax $1069.20 monthly $89.10.  Adding these four monthly  amounts equals $1054.47. NEED PCCD correcting escrows/ETIA, along with letter of explanation and proof of delivery to borrower.

7000-2657

8/21/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/21/2019: Received PCCD, borrower letter, and proof of delivery, reflecting corrected ETIA and Escrow sections of CD.

Compensating Factors 1. 691 FICO is 11 points greater than the minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. 24.90% DTI; 18.10% lower than 43.00% program mazimum

Cured

Compliance

EG2

8/19/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537655

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing documentation to evidence the borrower transferred the funds needed to close to a personal bank account from their business account as required by the lender guidelines.

7000-2691

8/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

waived at 90% LTV or less per guidelines.

Compensating Factors 1. 691 FICO is 11 points greater than the minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. 24.90% DTI; 18.10% lower than 43.00% program mazimum

Cured

Credit

EG1

8/19/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430592961

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: DTI is 51.01% vs program guideline maximum DTI of 50.00%Compensating Factors:1. 763 FICO, 123 points greater than program guideline minimum FICO of 6402. 70.204% LTV, 14.796% less than program guideline maximum LTV of 85.00%3. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement

7000-2780

8/23/2019

Waived/Exception Granted

Compensating Factors: 1. 763 FICO, 123 points greater than program guideline minimum FICO of 640 2. 70.204% LTV, 14.796% less than program guideline maximum LTV of 85.00% 3. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement

Waived

Credit

EG2

8/23/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592961

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2760

8/27/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/27/2019: Received PCCD, borrower letter, and proof of delivery, reflecting seller-paid fees per final Alta Settlement Statement.

Compensating Factors: 1. 763 FICO, 123 points greater than program guideline minimum FICO of 640 2. 70.204% LTV, 14.796% less than program guideline maximum LTV of 85.00% 3. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

8/23/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592961

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

UPDATE 08/27/2019: Received PCCD, borrower letter, reimbursement check in the amount of $178.00, and proof of delivery. However, after factoring in the $178.00 reimbursement, the loan fails the TRID Reimbursement Amount Test by $10.00: This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $178.00, is not sufficient to reimburse the consumer the amount by which the tolerances were exceeded, $188.00.This loan failed TRID zero fee tolerance.  Appraisal Fee increased on Loan Estimate dated 08/02/2019 and the Credit Report Fee increased on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $60.00.

7000-2761

8/30/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/30/2019: Received PCCD, borrower letter, reimbursement checks totalling $188.00, and proof of delivery.

Compensating Factors: 1. 763 FICO, 123 points greater than program guideline minimum FICO of 640 2. 70.204% LTV, 14.796% less than program guideline maximum LTV of 85.00% 3. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

8/23/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592961

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID 10% fee tolerance.  Recording Fee increased on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that in total cannot increase more than 10% test. (12 CFR 1026.19(e)(3)(ii))The loan contains third-party services that the consumer was permitted to shop for and the charges exceed the good faithtolerance according to 1026.19(e)(3)(ii). The final charges that in total cannot increase more than 10% ($716.50) exceed thecomparable charges ($535.00) by more than 10%. Total amount $128.00.

7000-2762

8/27/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/27/2019: Received PCCD, borrower letter, reimbursement check for $178.00, and proof of delivery.

Compensating Factors: 1. 763 FICO, 123 points greater than program guideline minimum FICO of 640 2. 70.204% LTV, 14.796% less than program guideline maximum LTV of 85.00% 3. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

8/23/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592961

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Licensing/Registration check returned the following results as of the application date of XXXX:  Loan Originator's NMLS #XXXX reflects Loan Originator is NOT Authorized to Represent Company NMLS #XXXX.

7000-2763

8/27/2019

Waived/Exception Granted

Compensating Factors: 1. 763 FICO, 123 points greater than program guideline minimum FICO of 640 2. 70.204% LTV, 14.796% less than program guideline maximum LTV of 85.00% 3. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

8/23/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592962

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Use of funds for reserves (not for income) from un-sourced deposits from business account on 06/14/2019 of $5,600.00 and 07/10/2019 of $3,000.00 dollars vs program requirement that all large deposits must be documented from an acceptable sourceCompensating Factors:1. 777 FICO scores, 97 points greater than program guideline minimum FICO scores of 6802. Owner of the same business for the past 8 years3. No public records4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

7000-3229

9/27/2019

Waived/Exception Granted

client exception approval with compensating factors

Compensating Factors: 1. 777 FICO scores, 97 points greater than program guideline minimum FICO scores of 680 2. Owner of the same business for the past 8 years 3. No public records 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Waived

Credit

EG2

9/27/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592962

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender Credit was removed on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits($385.00).

7000-3214

9/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Received CoC for 9/6/19 reflecting change in pricing and removal of lender credit. Retested in CE and passes

Compensating Factors: 1. 777 FICO scores, 97 points greater than program guideline minimum FICO scores of 680 2. Owner of the same business for the past 8 years 3. No public records 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG1

9/27/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592962

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  There is a $200.00 invoice in file for 1004d completion report paid by the borrower on 08/14/2019. However, the disbursement was not disclosed on the XXXX final closing disclosure. Need post consummation closing disclosure with borrower letter and proof of delivery, adding the $200.00 1004d appraisal fee. Note: The addition of the fee will cause a $200.00 TRID failure.

7000-3239

10/2/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/02/2019: Received PCCD, reimbursement check, borrower letter, and proof of delivery.

Compensating Factors: 1. 777 FICO scores, 97 points greater than program guideline minimum FICO scores of 680 2. Owner of the same business for the past 8 years 3. No public records 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

9/27/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592962

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure: The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3240

9/30/2019

Waived/Exception Granted

Compensating Factors: 1. 777 FICO scores, 97 points greater than program guideline minimum FICO scores of 680 2. Owner of the same business for the past 8 years 3. No public records 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

9/27/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592965

XXXX

XXXX

XXXX

Credit - Credit

Client approved exception for program requirement of at least 3 tradelines rated at minimum 12 months with 2 active within 12 months of the credit date. Borrower has a VOM and two active revolving accounts rated 11 and 7 months' and 2 closed accounts.Compensating Factors:1. 717 credit score; 17 point above minimum credit score of 700 as required by guidelines2. 38.757% LTV; 51.243% below 90% maximum3. Mortgage history is 0x30 for 12 months  4. No public records5. Borrower has been self-employed for the last 18.5 years6. DTI ratio of 16.409%; 26.591% less than 43% maximum

7000-3053

9/17/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 717 credit score; 17 point above minimum credit score of 700 as required by guidelines 2. 38.757% LTV; 51.243% below 90% maximum 3. Mortgage history is 0x30 for 12 months   4. No public records 5. Borrower has been self-employed for the last 18.5 years 6. DTI ratio of 16.409%; 26.591% less than 43% maximum

Waived

Credit

EG2

9/17/2019

Primary Residence

FL

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430592965

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender Credit was reduced on Loan Estimate dated XXXX and balance removed on Loan Estimate dated XXXX all without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 2This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits($4,800.00).

7000-3054

9/19/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 09/19/2019: Received valid 08/21/19 & 08/22/19 COC's.

Compensating Factors: 1. 717 credit score; 17 point above minimum credit score of 700 as required by guidelines 2. 38.757% LTV; 51.243% below 90% maximum 3. Mortgage history is 0x30 for 12 months   4. No public records 5. Borrower has been self-employed for the last 18.5 years 6. DTI ratio of 16.409%; 26.591% less than 43% maximum

Cured

Compliance

EG1

9/17/2019

Primary Residence

FL

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG1

EG1

EG1

10/30/2019

430537663

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2829

9/6/2019

Waived/Exception Granted

Compensating Factors: 1. 27 months reserves, 22 months greater than program guideline 5 months reserves requirement 2. 700 FICO Score, 60 points greater than program guideline minimum FICO of 640 3. The primary borrower’s has been employed with the same employer for the past 20 years

Waived

Compliance

EG2

8/28/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537663

XXXX

XXXX

XXXX

Credit - Income and Assets

The recalculated income of $4,419.32 resulted in a DTI of 54.67%. The Lender excluded the primary borrower's 2018 Schedule C loss of $892.00

7000-2821

9/6/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

sch C is secondary - exclude per FNMA B3-3 Income Assessment

Compensating Factors: 1. 27 months reserves, 22 months greater than program guideline 5 months reserves requirement 2. 700 FICO Score, 60 points greater than program guideline minimum FICO of 640 3. The primary borrower’s has been employed with the same employer for the past 20 years

Cured

Credit

EG1

8/28/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537663

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Sales or Purchase Contract. Unable to review transaction terms: purchase price, buyer, seller, broker information, property address or possible seller concessions.

7000-2822

9/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 27 months reserves, 22 months greater than program guideline 5 months reserves requirement 2. 700 FICO Score, 60 points greater than program guideline minimum FICO of 640 3. The primary borrower’s has been employed with the same employer for the past 20 years

Cured

Credit

EG1

8/28/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537663

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client Approved Exception: Allow the omission  of the  XXXX mortgage from the DTI ratio due to the co-mortgagor  is the borrower's son and has been making the mortgage payments for 6 months and has one 30-day mortgage late in the last 12 months (10/2018) vs program guideline requirement to exclude mortgage debts from the borrowers DTI ratio, the lender must obtain most recent 12 months' canceled checks (or bank statements) from the other party missing the payments that document a 12 month payment history with no delinquent paymentsCompensating Factors:1. 27 months reserves, 22 months greater than program guideline 5 months reserves requirement2. 700 FICO Score, 60 points greater than program guideline minimum FICO of 6403. The primary borrowers has been employed with the same employer for the past 20 years

7000-2817

8/28/2019

Waived/Exception Granted

Compensating Factors: 1. 27 months reserves, 22 months greater than program guideline 5 months reserves requirement 2. 700 FICO Score, 60 points greater than program guideline minimum FICO of 640 3. The primary borrower’s has been employed with the same employer for the past 20 years

Waived

Credit

EG2

8/28/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537663

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing a verbal VOE within 10 business days prior to the Note Date for primary borrower with XXXX, Inc.///Update 9/6/2019 Verbal VOE for the primary r borrower's employment with XXXX Inc. but it is not dated and it cannot be verified it was completed within 10 business days prior to the Note date.

7000-2818

9/11/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 27 months reserves, 22 months greater than program guideline 5 months reserves requirement 2. 700 FICO Score, 60 points greater than program guideline minimum FICO of 640 3. The primary borrower’s has been employed with the same employer for the past 20 years

Cured

Credit

EG1

8/28/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430537664

XXXX

XXXX

XXXX

Property - Collateral

Missing copy of appraisal. No appraisal/valuation was located in the file; unable to calculate LTV/CLTV.

7000-2495

8/12/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

08/12/2019: Received appraisal.

Compensating Factors: 1. 11.877% DTI, 31.123% less than program guideline maximum DTI of 43.00% 2. 761 FICO scores, 81 points greater than program guideline minimum FICO scores of 680 3. 15 months reserves, 12 greater than program guideline 3 months reserves requirement 4. No public records 5. Excellent mortgage payment history

Cured

Property

EG1

8/7/2019

Primary Residence

CT

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537664

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Wire Transfer Fee added for $50.00 and Municipal Lien Search increased by $230.00 on Initial Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $280.00.

7000-2498

8/14/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 08/14/2019: Received PCCD, borrower letter, reimbursement check, and proof of delivery.

Compensating Factors: 1. 11.877% DTI, 31.123% less than program guideline maximum DTI of 43.00% 2. 761 FICO scores, 81 points greater than program guideline minimum FICO scores of 680 3. 15 months reserves, 12 greater than program guideline 3 months reserves requirement 4. No public records 5. Excellent mortgage payment history

Cured

Compliance

EG2

8/7/2019

Primary Residence

CT

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537664

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. ETIA on final CD reflects a total of $537.95, which is off by $10.00 of the monthly escrow costs of $527.95. Need documentation reflecting HOA costs. Also need Post Consummation Closing Disclosure reflecting "HOA Dues" in the "Other" description of ETIA along with borrower explanation letter and proof of delivery of all documents to the borrower.

7000-2499

8/13/2019

Waived/Exception Granted

Compensating Factors: 1. 11.877% DTI, 31.123% less than program guideline maximum DTI of 43.00% 2. 761 FICO scores, 81 points greater than program guideline minimum FICO scores of 680 3. 15 months reserves, 12 greater than program guideline 3 months reserves requirement 4. No public records 5. Excellent mortgage payment history

Waived

Compliance

EG2

8/7/2019

Primary Residence

CT

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG3

EG1

10/30/2019

430537667

XXXX

XXXX

XXXX

Property - Collateral

Missing appraisal and unable to calculate subject property LTV/CLTV.

7000-2497

8/9/2019

Property condition cleared

Full appraisal has been added to the file.

Compensating Factors: 1. 649 credit score; 9 points above minimum credit score of 640 as required by guidelines 2. 65% LTV; 5% below 70% maximum 3. Mortgage history is 0x30 for 12 months  4. No public records 5. Borrower has been self-employed for the last 30 years 6. DTI ratio of 0.712%; 49.288% less than 50% maximum

Cured

Property

EG1

8/8/2019

Investment Property

FL

x/xx/xxxx

Refinance - cash out

Not covered / exempt

EG3

EG1

EG1

EG1

EG1

EG1

EG3

EG1

10/30/2019

430592970

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On CD issued XXXX, under the Estimated Taxes, Insurance and Assessments section on page one, This estimate includes, Other is missing a description of the other assessments that are also included in escrow.  Need Post Consummation CD with a description of the other assessments that are also included in escrow and explanation letter to borrower with proof of method of delivery of all to borrower.

7000-3367

10/4/2019

Waived/Exception Granted

Compensating Factors: 1. 16.030% DTI, 26.97% less than program guideline maximum DTI of 43.00% 2. 773 FICO scores, 93 points less than program guideline minimum FICO scores of 680 3. 39 months reserves, 35 months greater than program guideline 4 months reserves requirement (3 months for subject and 1 month for investment)

Waived

Compliance

EG2

10/4/2019

Primary Residence

PA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537669

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2902

9/10/2019

Waived/Exception Granted

Compensating Factors: 1. 31.81% DTI, 18.19% less than program guideline maximum DTI of 50.00% 2. 80.00% LTV, 10.00% less than program guideline maximum LTV of 90.00% 3. 12 months reserves, 9 months greater than program guideline 3 months reserves requirement 4. 716 FICO scores, 36 points greater than program guideline minimum FICO scores of 680 5. Owner of the same business for 14 years

Waived

Compliance

EG2

9/6/2019

Primary Residence

GA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592975

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Allow funds for closing costs paid from borrowers business account vs program guideline requirement that business funds must be transferred to borrowers personal accountCompensating Factors:1. 795 credit score; 155 points greater than 640 program minimum2. 21 months reserves; 18 months greater than3 months program minimum3. 31.16% DTI; 11.84% less than 43.00% program minimum4. Borrower has been self-employed/Owner of the same business for 32 years

7000-3156

9/24/2019

Waived/Exception Granted

Client exception approval granted with compensating factors

Compensating Factors: 1. 795 credit score; 155 points greater than 640 program minimum 2. 21 months reserves; 18 months greater than3 months program minimum 3. 31.16% DTI; 11.84% less than 43.00% program minimum 4. Borrower has been self-employed/Owner of the same business for 32 years

Waived

Credit

EG2

9/24/2019

Primary Residence

DE

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592975

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. Need Post Consummation Closing Disclosure correcting the fees.  Closing Disclosure in file dated XXXX reflects Title Fees Paid to XXXX and listed in Section C and need to be moved to Section B per the Service Providers List.

7000-3151

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 795 credit score; 155 points greater than 640 program minimum 2. 21 months reserves; 18 months greater than3 months program minimum 3. 31.16% DTI; 11.84% less than 43.00% program minimum 4. Borrower has been self-employed/Owner of the same business for 32 years

Waived

Compliance

EG2

9/24/2019

Primary Residence

DE

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592975

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On CD issued XXXX, under the Estimated Taxes, Insurance and Assessments section on page one, This estimate includes, Other is missing a description of the other assessments that are also included in escrow.  Need Post Consummation CD with a description of the other assessments that are also included in escrow and explanation letter to borrower with proof of method of delivery of all to borrower.

7000-3131

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 795 credit score; 155 points greater than 640 program minimum 2. 21 months reserves; 18 months greater than3 months program minimum 3. 31.16% DTI; 11.84% less than 43.00% program minimum 4. Borrower has been self-employed/Owner of the same business for 32 years

Waived

Compliance

EG2

9/24/2019

Primary Residence

DE

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592976

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. Need Post Consummation Closing Disclosure correcting the fees.  Closing Disclosure in file dated XXXX reflects Title Fees Paid to XXXX and listed in Section C and need to be moved to Section B per the Service Providers List.

7000-3163

9/26/2019

Waived/Exception Granted

Compensating Factors 1. 722 FICO is 42 Points greater than the minimum of 680 required by the lender guidelines 2. 0x30 housing history for 12 months 3.44.44% LTV; 45.56% less than 90.00% program maximum

Waived

Compliance

EG2

9/25/2019

Primary Residence

IL

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592977

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Added 09/16/2019:  The loan contains errors within one or more TRID disclosure.  On CD issued XXXX, under the Estimated Taxes, Insurance and Assessments section on page one, This estimate includes, Other is missing a description of the other assessments that are also included in escrow.  Need Post Consummation CD with a description of the other assessments that are also included in escrow and explanation letter to borrower with proof of method of delivery of all to borrower.  Condition added upon post closing review.

7000-3048

10/17/2019

Waived/Exception Granted

Compensating Factors: 1. 71 months reserves, 68 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 12 years 3. No public records

Waived

Compliance

EG2

9/18/2019

Primary Residence

PA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592977

XXXX

XXXX

XXXX

Credit - Income and Assets

The recalculated income of $x,xxx.xx resulted in a DTI of 71.79% which exceeded loan program guideline maximum DTI of 50.00%. The Lender failed to provide documentation to evidence the inclusion of  transfers for the months of 04/2019 through 12/2018 with XXXX account ending in xxxx. The loan is subject to income recalculation

7000-3071

10/18/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 71 months reserves, 68 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 12 years 3. No public records

Cured

Credit

EG1

9/18/2019

Primary Residence

PA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592977

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing documentation to support transfer into XXXX account ending in xxxx for the following monthsApril 2019 in the amount of $18,455.00March 2019 in the amount of $19,110.00February 2019 in the amount of $11,990.00January 2019 in the amount of $14,000.00December 2018 in the amount of $8,870.00

7000-3072

10/18/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 71 months reserves, 68 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 12 years 3. No public records

Cured

Credit

EG1

9/18/2019

Primary Residence

PA

x/xx/xxxx

Refinance - cash out

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592978

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing evidence of the gift funds transfer of $31,000.00 from donor to Title/Escrow at closing.  Subject to re-calculation of reserves upon receipt.

7000-3091

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

wire transfer received

Compensating Factors 1. Owner of the same business for the past 15 years 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00% 4. No public records 5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

Cured

Credit

EG1

9/19/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592978

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Allow use of XXXX statements instead of traditional bank statements. Borrower is the sole proprietor, who sells memorabilia and toys, and is paid via XXXX through sales on XXXX. Compensating Factors1. Owner of the same business for the past 15 years2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00%4. No public records5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

7000-3092

9/24/2019

Waived/Exception Granted

Seller granted exception with compensating factors

Compensating Factors 1. Owner of the same business for the past 15 years 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00% 4. No public records 5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

Waived

Credit

EG2

9/19/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592978

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3076

9/20/2019

Waived/Exception Granted

Compensating Factors 1. Owner of the same business for the past 15 years 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00% 4. No public records 5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

Waived

Compliance

EG2

9/19/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592978

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender credits decreased  on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specific andnon-specific lender credits ($1,487.82) does not exceed or equal the comparable sum of specific and non-specific lender credits($1,623.00).  Total amount $135.18.

7000-3077

9/26/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 09/26/2019: Received 08/28/2019 COC.

Compensating Factors 1. Owner of the same business for the past 15 years 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00% 4. No public records 5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

Cured

Compliance

EG1

9/19/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592978

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  IL Loan Brokerage Agreement and IL Loan Brokerage Disclosure Statement.

7000-3078

9/20/2019

Waived/Exception Granted

Compensating Factors 1. Owner of the same business for the past 15 years 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00% 4. No public records 5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

Waived

Compliance

EG2

9/19/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592978

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Subject is a non-arms length transaction per appraisal. Borrower is the tenant of the property being purchased.  Missing 2nd appraisal as required by guidelines  //  UPDATED 9/24/2019: contractual agreement between tenant and landlord is the business relationship.  Missing 2nd appraisal.

7000-3100

10/23/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Meets FNMA - No NOD on title. Need 2nd appraisal./// Client exception provided

Compensating Factors 1. Owner of the same business for the past 15 years 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00% 4. No public records 5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

Cured

Credit

EG1

9/19/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592978

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception in the loan file.  Client approved exception for Non-arms length transaction missing 2nd full appraisal vs program requirement for a full 2nd appraisal required on Non-arms length transaction. Compensating Factors1. Owner of the same business for the past 15 years2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00%4. No public records5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

7000-3705

10/23/2019

Waived/Exception Granted

Compensating Factors 1. Owner of the same business for the past 15 years 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 43.86% DTI, 6.14% less than program guideline maximum DTI of 50.00% 4. No public records 5. 669 FICO scores, 29 points greater than program guideline minimum FICO scores of 640

Waived

Credit

EG2

9/19/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537676

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing documentation to evidence the borrower transferred the funds used for closing from a business account to a personal account.

7000-2715

8/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 36.00% DTI, 14% less than program guideline maximum DTI of 50.00% 2. 775 FICO, 55 points greater than program guideline minimum FICO of 720 3. Owner of the same business for the past 12 years

Cured

Credit

EG1

8/19/2019

Investment Property

CA

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG1

EG3

EG1

EG1

EG1

EG1

EG1

10/30/2019

430537676

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing final signed HUD 1 Settlement Statement

7000-2708

8/28/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 36.00% DTI, 14% less than program guideline maximum DTI of 50.00% 2. 775 FICO, 55 points greater than program guideline minimum FICO of 720 3. Owner of the same business for the past 12 years

Cured

Credit

EG1

8/19/2019

Investment Property

CA

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG1

EG3

EG1

EG1

EG1

EG1

EG1

10/30/2019

430537678

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender Credit was removed on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits ($3,564.00).

7000-2869

9/6/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 09/06/2019: Received 08/16/2019 COC with modify lock for pricing change to PAR and Lender paid broker fee per borrower request.

Compensating Factors: 1. 2.250% DTI, 40.75% less than program guideline maximum DTI of 43.00% 2. 743 FICO Scores, 63 points greater than program guideline minimum FICO of 680 3. Owner of the same business for 7 years 4. No public records

Cured

Compliance

EG1

9/3/2019

Primary Residence

LA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537678

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:   Loan Option Disclosure/Anti-Steering Disclosure, LA Loan Brokerage Agreement and Disclosure Statement and LA Mortgage Loan Origination Agreement.

7000-2870

9/5/2019

Waived/Exception Granted

Compensating Factors: 1. 2.250% DTI, 40.75% less than program guideline maximum DTI of 43.00% 2. 743 FICO Scores, 63 points greater than program guideline minimum FICO of 680 3. Owner of the same business for 7 years 4. No public records

Waived

Compliance

EG2

9/3/2019

Primary Residence

LA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537678

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2888

9/5/2019

Waived/Exception Granted

Compensating Factors: 1. 2.250% DTI, 40.75% less than program guideline maximum DTI of 43.00% 2. 743 FICO Scores, 63 points greater than program guideline minimum FICO of 680 3. Owner of the same business for 7 years 4. No public records

Waived

Compliance

EG2

9/3/2019

Primary Residence

LA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG1

EG1

EG3

EG2

EG1

EG1

10/30/2019

430537680

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On CD issued XXXX, under the Assumption section on page four, neither option is marked.  Need Post Consummation CD with one of the options marked under Assumption section on page four and explanation letter to borrower with proof of method of delivery of all to borrower.

7000-2871

9/5/2019

Waived/Exception Granted

Compensating Factors: 1. 766 FICO Score, 46 points greater than program guideline minimum FICO of 720 2. 85.00% LTV, 5% less than program guideline maximum LTV of 90.00% 3. Conservatives attitude toward using credit 4. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 5. No public records

Waived

Compliance

EG2

9/4/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537680

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-2873

9/5/2019

Waived/Exception Granted

Compensating Factors: 1. 766 FICO Score, 46 points greater than program guideline minimum FICO of 720 2. 85.00% LTV, 5% less than program guideline maximum LTV of 90.00% 3. Conservatives attitude toward using credit 4. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 5. No public records

Waived

Compliance

EG2

9/4/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430537683

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure (CD) in file dated XXXX do not match the Seller Paid fees on the XXXX Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-2718

8/26/2019

Waived/Exception Granted

Compensating Factors: 1. 695 credit score; 15 points above minimum credit score of 680 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 5 years 4. DTI ratio of 24.37%; 25.63% less than 50% maximum

Waived

Compliance

EG2

8/20/2019

Primary Residence

GA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537683

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID timing of disclosures.  APR Variance is more than .125% on Closing Disclosure (CD) dated XXXX, resulting in the below TRID Timing Violation.Revised Closing Disclosure Timing Requirements - XXXX - 2This loan failed the revised closing disclosure delivery date test (waiting period required).(12 CFR 1026.19(f)(2)(ii))The revised closing disclosure delivery requires a new waiting period and The revised closing disclosure delivery date is provided and the revised closing disclosure method of delivery is marked as either:?"USPS First Class Mail" or "Electronic Delivery" or blank, and the revised closing disclosure delivery date is less than six business days (counting all calendar days except Sunday and specified legal public holidays) before the consummation date, or closing / settlement date if no consummation date is provided, of the transaction; or?"In Person" and the revised closing disclosure delivery date is less than three business days (counting all calendar days except Sunday and specified legal public holidays) before the consummation date, or closing / settlement date if no consummation date is provided, of the transaction; orThe revised closing disclosure receipt date is provided and the revised closing disclosure receipt date is less than three business days (counting all calendar days except Sunday and specified legal public holidays) before the consummation date, or closing / settlement date if no consummation date is provided, of the transaction.Changes before consummation requiring a new waiting period. If one of the following disclosures provided under 1026.19(f)(1)(i) becomes inaccurate in the following manner before consummation, the creditor shall ensure that the consumer receives corrected disclosures containing all changed terms in accordance with the requirements of 1026.19(f)(1)(ii)(A):(A) The annual percentage rate disclosed under 1026.38(o)(4) becomes inaccurate, as defined in 1026.22.(B) The loan product is changed, causing the information disclosed under 1026.38(a)(5)(iii) to become inaccurate.(C) A prepayment penalty is added, causing the statement regarding a prepayment penalty required under 1026.38(b) to become inaccurate.The creditor shall ensure that the consumer receives the disclosures required under 1026.19(f)(1)(i) no later than three business days before consummation.

7000-2719

8/26/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Per legal counsel, the lender is not required to provide a new three day waiting period if the APR decreases more than .125%, only if it increases. Condition cleared

Compensating Factors: 1. 695 credit score; 15 points above minimum credit score of 680 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 5 years 4. DTI ratio of 24.37%; 25.63% less than 50% maximum

Cured

Compliance

EG1

8/20/2019

Primary Residence

GA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537683

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  On CD issued XXXX, under the Estimated Taxes, Insurance and Assessments section on page one, This estimate includes, Other is missing a description of the other assessments that are not in escrow.  Need Post Consummation CD with a description of the other assessments that are not in escrow and explanation letter to borrower with proof of method of delivery of all to borrower.

7000-2707

8/26/2019

Waived/Exception Granted

Compensating Factors: 1. 695 credit score; 15 points above minimum credit score of 680 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 5 years 4. DTI ratio of 24.37%; 25.63% less than 50% maximum

Waived

Compliance

EG2

8/20/2019

Primary Residence

GA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430537683

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception for the program minimum requirement loan amount of $100,000.00. The subject loan amount is $XXXX Compensating Factors:1. 695 credit score; 15 points above minimum credit score of 680 as required by guidelines2. No public records3. Borrower has been self-employed for the last 5 years4. DTI ratio of 24.37%; 25.63% less than 50% maximum

7000-2726

8/20/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 695 credit score; 15 points above minimum credit score of 680 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 5 years 4. DTI ratio of 24.37%; 25.63% less than 50% maximum

Waived

Credit

EG2

8/20/2019

Primary Residence

GA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430592986

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3069

9/19/2019

Waived/Exception Granted

Compensating Factors: 1. 25.10% DTI, 24.90% less than program guideline maximum DTI of 50.00% 2. 705 FICO Scores, 25 points greater than program guideline minimum FICO scores of 680 3. 10 months reserves, 5 months greater than program guideline 5 months reserves requirement 4. No public records

Waived

Compliance

EG2

9/19/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592987

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception to allow down payment coming from the borrower's business account vs program requirement that if funds in a business bank or brokerage account must be transferred to the borrower's personal account. Compensating Factors:1. 35.07% DTI, 14.93% less than program guideline maximum DTI of 50.00%2. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 3. 684 FICO Scores, 24 points greater than program guideline minimum FICO scores of 660

7000-3144

9/23/2019

Waived/Exception Granted

Compensating Factors: 1. 35.07% DTI, 14.93% less than program guideline maximum DTI of 50.00% 2. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 3. 684 FICO Scores, 24 points greater than program guideline minimum FICO scores of 660

Waived

Credit

EG2

9/21/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430592987

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3108

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 35.07% DTI, 14.93% less than program guideline maximum DTI of 50.00% 2. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 3. 684 FICO Scores, 24 points greater than program guideline minimum FICO scores of 660

Waived

Compliance

EG2

9/21/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430592987

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  IL Civil Union Addendum to Uniform Residential Loan Application completed with boxes marked and signed by borrower, IL Loan Brokerage Agreement, and IL Loan Brokerage Disclosure Statement.

7000-3109

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 35.07% DTI, 14.93% less than program guideline maximum DTI of 50.00% 2. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 3. 684 FICO Scores, 24 points greater than program guideline minimum FICO scores of 660

Waived

Compliance

EG2

9/21/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430592987

XXXX

XXXX

XXXX

Property - Collateral

Missing Appraiser's E&O Insurance for appraiser XXXX.

7000-3117

10/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 35.07% DTI, 14.93% less than program guideline maximum DTI of 50.00% 2. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 3. 684 FICO Scores, 24 points greater than program guideline minimum FICO scores of 660

Cured

Property

EG1

9/21/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430592987

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing documentation to evidence that the borrower's is the sole owner of a XXXX account ending in xxxx and xxxx.  A transfer of $80,000.00 on 09/11/2019 from XXXX business account ending in xxxx to a XXXX account ending in xxxx and a transfer of $11,000.00 on 09/12/2019 from XXX business account ending in xxxx to a XXXX account ending in xxxx. Loan is subject to assets and reserves recalculation

7000-3118

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 35.07% DTI, 14.93% less than program guideline maximum DTI of 50.00% 2. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 3. 684 FICO Scores, 24 points greater than program guideline minimum FICO scores of 660

Cured

Credit

EG1

9/21/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430592987

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID 10% fee tolerance.  This loan failed the charges that in total cannot increase more than 10% test. (12 CFR 1026.19(e)(3)(ii))The loan contains third-party services that the consumer was permitted to shop for and the charges exceed the good faith tolerance according to 1026.19(e)(3)(ii). The final charges that in total cannot increase more than 10% ($180.00) due to the Recording Fee exceed the comparable charges ($120.00) by more than 10%.

7000-3119

9/27/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 09/27/2019: Received PCCD, reimbursement check, borrower letter, and proof of delivery.

Compensating Factors: 1. 35.07% DTI, 14.93% less than program guideline maximum DTI of 50.00% 2. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement 3. 684 FICO Scores, 24 points greater than program guideline minimum FICO scores of 660

Cured

Compliance

EG2

9/21/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430537685

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing Grant Deed to confirm vesting.

7000-2856

9/5/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 09/05/2019: Received executed and notarized Warranty Deed.

Compensating Factors: 1. 32.25% DTI, 17.75% less than program guideline maximum DTI of 50.00% 2. 60.00% LTV, 30% less than program guideline maximum LTV of 90.00% 3. 750 FICO Score, 70 points greater than program guideline minimum FICO of 680 4. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG1

8/30/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG1

EG1

EG1

10/30/2019

430537685

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Borrower has 1 active tradeline and 1 inactive tradeline for at least 12 months vs program minimum requirement of 2 active tradelines and 1 inactive tradeline for at least 12 monthsCompensating Factors:1. 32.25% DTI, 17.75% less than program guideline maximum DTI of 50.00%2. 60.00% LTV, 30% less than program guideline maximum LTV of 90.00%3. 750 FICO Score, 70 points greater than program guideline minimum FICO of 6804. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement

7000-2863

8/30/2019

Waived/Exception Granted

Compensating Factors: 1. 32.25% DTI, 17.75% less than program guideline maximum DTI of 50.00% 2. 60.00% LTV, 30% less than program guideline maximum LTV of 90.00% 3. 750 FICO Score, 70 points greater than program guideline minimum FICO of 680 4. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement

Waived

Credit

EG2

8/30/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG1

EG1

EG1

10/30/2019

430537685

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Lender to provide evidence of monthly obligations for HOA dues for the property located at XXXX

7000-2864

9/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 32.25% DTI, 17.75% less than program guideline maximum DTI of 50.00% 2. 60.00% LTV, 30% less than program guideline maximum LTV of 90.00% 3. 750 FICO Score, 70 points greater than program guideline minimum FICO of 680 4. 9 months reserves, 6 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

8/30/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG1

EG1

EG1

10/30/2019

430592993

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure and ID Reserve Account Disclosure.

7000-3221

10/1/2019

Waived/Exception Granted

Compensating Factors: 1. 31.52% DTI, 18.48% less than program guideline maximum DTI of 50.00% 2. 724 FICO scores, 84 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for 12 years and 4 months 4. No public records

Waived

Compliance

EG2

9/27/2019

Primary Residence

ID

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592993

XXXX

XXXX

XXXX

Credit - Credit

Missing verification of housing history for the departing residence not to exceed 1X30 in the past 12 months located at XXXX //  UPDATED 10/8/2019:  HUD1 shows property in wife's name, however, this is the borrower's primary residence - 12 month housing history required per guidelines.

7000-3225

10/10/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

xxxx payment paid from borr business bank statements

Compensating Factors: 1. 31.52% DTI, 18.48% less than program guideline maximum DTI of 50.00% 2. 724 FICO scores, 84 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for 12 years and 4 months 4. No public records

Cured

Credit

EG1

9/27/2019

Primary Residence

ID

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592993

XXXX

XXXX

XXXX

Credit - Income and Assets

The verified assets of $xxx,xxx.xx are insufficient to satisfy the required total funds from the borrowers of $XXXX. Loan is subject to assets and reserves recalculation  //  UPDATED 10/2/2019: Verified assets: $x,xxx EMD(gift funds from spouse) + $xxx,xxx.xx (sale proceeds) + $x,xxx.xx (XXXX x4005) = $xxx,xxx.xx less total funds into transaction $XXXX (HUD1 deposit $x,xxx + sale proceeds deposit $xxx,xxx.xx + short to close $xx,xxx.xx) = Shortage of $XXXX.  Still missing additional asset documentation to support shortage of $XXXX + 3 month reserves $x,xxx.xx = total shortage $XXXX.   ///   UPDATED 10/8/2019: Rec'd XXXX xxxxxx and100% access letter - unable to consider the $14,250.00 deposit from XXXX (no supporting documentation provided).  Additionally, the $31,250.00 receipt for the 'satisfied loan' was not considered as it is not reflected in the XXXX statement provided.  Updated verified assets $xxx,xxx.xx less funds into transaction $XXXX = net reserves $x,xxx.xx and is short of $x,xxx.xx (3 months pitia $x,xxx.xx - x,xxx.xx).

7000-3226

10/10/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 31.52% DTI, 18.48% less than program guideline maximum DTI of 50.00% 2. 724 FICO scores, 84 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for 12 years and 4 months 4. No public records

Cured

Credit

EG1

9/27/2019

Primary Residence

ID

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592993

XXXX

XXXX

XXXX

Credit - Income and Assets

The Minimum Reserve Requirement of $8,402.25 has not been met   //   UPDATED 10/8/2019: Rec'd XXXX xx4630 and100% access letter - unable to consider the $14,250.00 deposit from XXXX (no supporting documentation provided).  Additionally, the $31,250.00 receipt for the 'satisfied loan' was not considered as it is not reflected in the XXXX statement provided.  Updated verified assets $xxx,xxx.xx less funds into transaction $XXXX = net reserves $x,xxx.xx and is short of $x,xxx.xx (3 months pitia $x,xxx.xx - x,xxx.xx).

7000-3227

10/10/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 31.52% DTI, 18.48% less than program guideline maximum DTI of 50.00% 2. 724 FICO scores, 84 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for 12 years and 4 months 4. No public records

Cured

Credit

EG1

9/27/2019

Primary Residence

ID

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592993

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing CPA letter regarding use of business assets in XXXX Business Checking Acct #xxxx and the impact, if any, it would have on the borrower's business.

7000-3228

10/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

guideline change 7.8.19 biz funds used for down payment, closing for 90% >TV or less do not require CPA letter.

Compensating Factors: 1. 31.52% DTI, 18.48% less than program guideline maximum DTI of 50.00% 2. 724 FICO scores, 84 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for 12 years and 4 months 4. No public records

Cured

Credit

EG1

9/27/2019

Primary Residence

ID

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  CT Mortgage Rate Lock-In Agreement.

7000-3126

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Waived

Compliance

EG2

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Credit - Legal Documentation

Missing Legal description to the Mortgage reflected as Exhibit A on page 2 of 10 of Mortgage dated XXXX.  Need complete copy of Mortgage inclusive of all pages, signed and notarized reflecting Exhibit A.

7000-3123

10/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 10/03/2019: Received all pages of Open-End Mortgage Deed with legal description and Inter Vivos Revocable Trust Rider.

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3133

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing evidence of two months of rent receipts for the following rental property XXXX. Only the receipt of one month's rental payment documentation with the bank statement with XXXX xxxxxx  has been provided. Loan is subject to income recalculation

7000-3134

9/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Subject property is on xx.xx acres vs program maximum of 15 acresSeller Approved Exception: DTI is 51.87% vs program guideline maximum DTI of 50.00%Compensating Factors:1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00%3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 7204. No public records

7000-3135

9/23/2019

Waived/Exception Granted

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Waived

Credit

EG2

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure: Missing payee name for the $150.00 Appraisal Field Review Fee listed on the XXXX final Closing Disclosure. Need Post Consummation Closing Disclosure with borrower letter and proof of delivery, adding the payee name for the $150.00 Appraisal Field Review Fee.

7000-3130

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Waived

Compliance

EG2

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing June 2019, December 2018 and September 2018 business bank statements from XXXX account ending in xxxx. Loan is subject to income recalculation

7000-3138

9/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

updated claculation worksheet

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing complete (all pages) for the months of 07/2019, 05/2019, 04/2019, 03/2019, 02/2019, 01/2019, 11/2018, 10/2018 and 08/2018 from XXXX account ending in xxxx. Loan is subject to income recalculation

7000-3139

9/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592994

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing large deposit explanation in the amount of $12,387.50 on 06/28/2019 and $14,197.68 on 03/29/2019 into the borrower's business account with XXXX account ending in xxxx. Loan is subject to income recalculation

7000-3140

9/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 91 months reserves, 72 months greater than program guideline 19 months reserves requirement 2. 48.00% LTV, 37% less than program guideline maximum LTV of 85.00% 3. 770 FICO scores, 50 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/23/2019

Primary Residence

CT

x/xx/xxxx

Refinance - rate and term

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430592998

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing a signed letter of explanation and source for the  large deposit of $30,000.00 into the borrower's personal account with xxxx bank ending in xxxxx on 07/31/2019.

7000-3096

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

deducted large deposit from assets - still sufficient - reserves met.

Compensating Factors: 1. 38.04% DTI, 11.96% less than program guideline maximum DTI of 50.00% 2. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement 3. 746 FICO Scores, 26 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/19/2019

Investment Property

FL

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430592998

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Borrower's company, XXXX was formed 17 months ago (03/17/2018) vs program requirement that the borrower must have been continually self employed for two yearsCompensating Factors:1. 38.04% DTI, 11.96% less than program guideline maximum DTI of 50.00%2. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement3. 746 FICO Scores, 26 points greater than program guideline minimum FICO scores of 7204. No public records

7000-3097

9/20/2019

Waived/Exception Granted

Compensating Factors: 1. 38.04% DTI, 11.96% less than program guideline maximum DTI of 50.00% 2. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement 3. 746 FICO Scores, 26 points greater than program guideline minimum FICO scores of 720 4. No public records

Waived

Credit

EG2

9/19/2019

Investment Property

FL

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430592998

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Lender to provide evidence of monthly obligations for taxes, hazard insurance and HOA dues (if applicable), for the property located at XXXX

7000-3098

9/24/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 38.04% DTI, 11.96% less than program guideline maximum DTI of 50.00% 2. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement 3. 746 FICO Scores, 26 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/19/2019

Investment Property

FL

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430592998

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing copy of Note and final signed closing disclosure for the purchase of the borrower's primary residence on xxxx and located at XXXX

7000-3099

9/24/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 38.04% DTI, 11.96% less than program guideline maximum DTI of 50.00% 2. 31 months reserves, 28 months greater than program guideline 3 months reserves requirement 3. 746 FICO Scores, 26 points greater than program guideline minimum FICO scores of 720 4. No public records

Cured

Credit

EG1

9/19/2019

Investment Property

FL

x/xx/xxxx

Purchase

Not covered / exempt

EG3

EG2

EG3

EG2

EG1

EG1

EG1

EG1

10/30/2019

430592999

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Finance Charges are understated.  The Collateral Desktop Analysis reflects payable to Lender in Section "A" with no proof in file that fee is a pass through fee for Lender resulting in the below TILA Finance Charge Violation.Federal TILAThis loan failed the TILA finance charge test.(12 CFR 1026.18(d)(1), transferred from 12 CFR 226.18(d)(1))The finance charge is $xxx,xxx.xx. The disclosed finance charge of $xxx,xxx.xx is not considered accurate because it is understated by more than $100.00.  Total Under Disclosed amount is -$150.00.

7000-3172

9/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Received attestation that CDA fee was paid through fee and not retained by the lender. cleared

Compensating Factors: 1. 701 credit score; 1 point above minimum credit score of 700 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 2 years 4. DTI ratio of 14.451%; 28.549% less than 43% maximum

Cured

Compliance

EG1

9/25/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG1

EG3

EG1

EG3

EG1

EG1

EG1

10/30/2019

430592999

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation.

7000-3173

9/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 701 credit score; 1 point above minimum credit score of 700 as required by guidelines 2. No public records 3. Borrower has been self-employed for the last 2 years 4. DTI ratio of 14.451%; 28.549% less than 43% maximum

Cured

Credit

EG1

9/25/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG1

EG3

EG1

EG3

EG1

EG1

EG1

10/30/2019

430593008

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3200

9/27/2019

Waived/Exception Granted

Compensating Factors: 1. 16.539% DTI, 26.461% less than program guideline maximum DTI of 43.00% 2. 808 FICO scores, 88 points greater than program guideline minimum FICO scores of 720 3. 8 months reserves, 5 months greater than program guideline 3 months reserves requirement 4. Owner of the same business for the past 3 years

Waived

Compliance

EG2

9/27/2019

Primary Residence

MI

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG2

EG2

EG1

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593010

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3189

9/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors 1. 685 FICO and is 5 points greater than minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. The borrower has been in the same line of business for 15 years

Cured

Credit

EG1

9/26/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593010

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.   The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3178

10/1/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/01/2019: Received PCCD, Seller CD, borrower letter, and proof of delivery.

Compensating Factors 1. 685 FICO and is 5 points greater than minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. The borrower has been in the same line of business for 15 years

Cured

Compliance

EG2

9/26/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593010

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  Lender over disclosed ETIA/Escrow collection on Final CD dated XXXX. Total ETIA and monthly escrow totals should be $1,335.53 not $1,369.06. Hazard Insurance premium of $4,343.89monthly is $361.99.  For Taxes, used Tax Certificate, shows annual Property tax amount of $10,057.40  monthly $838.12. HOA is $1,625.00-monthly $135.42, adding these monthly amounts equals $1,335.53. NEED PCCD correcting escrows/ETIA, along with letter of explanation and proof of method of delivery to borrower.

7000-3179

10/3/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/03/2019: Received PCCD, Seller CD, borrower letter, and proof of delivery.

Compensating Factors 1. 685 FICO and is 5 points greater than minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. The borrower has been in the same line of business for 15 years

Cured

Compliance

EG2

9/26/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593010

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing documentation to evidence the borrower has reserves in the amount of $xx,xxx.xx to meet the guideline reserve requirement (subject 3 months + 1 investment property).  //  UPDATE 9/30/2019 Received one month statement XXXX xxxxxx ending balance $5497.47 dated to 7/11/2019 - missing 2nd concurrent month.  Updated reserves value $xx,xxx.xx and does not meet minimum requirement of $17,178.88.

7000-3193

10/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors 1. 685 FICO and is 5 points greater than minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. The borrower has been in the same line of business for 15 years

Cured

Credit

EG1

9/26/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593010

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing the most recent 12 months bank statements for the borrower  to support the income used to qualify. File contains statements for XXXX xxxx June 2019 thru August 2019 only. Subject to recalculation of the debt to income ratios.  //  UPDATED 9/30/2019:  Only one statement from XXXX xxxxxx has been received (statement dated to 7/11/2019).  Missing balance of statements from this account.  Subject to re-calculation of income upon receipt. // UPDATED 10/1/2019: Missing eleven months bank statements from XXXX xxxxxxx in order to calculate the qualifying income.  Only one month of online statements from XXXX xxxxxxx have been provided (HAVE 7/12/19 thru 8/12/19 only).

7000-3196

10/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors 1. 685 FICO and is 5 points greater than minimum of 680 required by the guidelines 2. No public records 3. 0x30 housing history for the past 12 months 4. The borrower has been in the same line of business for 15 years

Cured

Credit

EG1

9/26/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593011

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3105

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 661 FICO Scores, 21 points greater than program guideline minimum FICO scores of 640 2. 45.15% DTI, 4.85% less than program guideline maximum DTI of 50.00% 3. Excellent mortgage payment history since inception on 09/2017 4. No public records

Waived

Compliance

EG2

9/20/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593011

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-3106

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 661 FICO Scores, 21 points greater than program guideline minimum FICO scores of 640 2. 45.15% DTI, 4.85% less than program guideline maximum DTI of 50.00% 3. Excellent mortgage payment history since inception on 09/2017 4. No public records

Waived

Compliance

EG2

9/20/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593011

XXXX

XXXX

XXXX

Credit - Credit

The loan file is missing 11 months rental rating for the borrowers current residence located at XXXX//Updated 09252019  Letter of explanation indicates the borrower was renting XXXX prior to this purchase.  Missing 11 month rental rating from landlord.

7000-3114

9/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 661 FICO Scores, 21 points greater than program guideline minimum FICO scores of 640 2. 45.15% DTI, 4.85% less than program guideline maximum DTI of 50.00% 3. Excellent mortgage payment history since inception on 09/2017 4. No public records

Cured

Credit

EG1

9/20/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593011

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing the12 month  mortgage history7/18 to 6/19  for the borrower's property located at XXXX. Maximum 1x30.//Updated 09252019 Statements copies and credit report provided were for XXXX of which the file already contains a 23 month rating on the credit report.  Missing a 12 month rating for XXXX.  ///  UPDATE 9/27/2019: DRIVE report shows property acquired x/xx/xxxx with 1st mortgage in the amount of $XXXX.  Missing most recent 12 month payment history or proof this mortgage was fully paid prior to 7/2018.

7000-3137

10/17/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Received letter from note holder reflecting all payment made on time

Compensating Factors: 1. 661 FICO Scores, 21 points greater than program guideline minimum FICO scores of 640 2. 45.15% DTI, 4.85% less than program guideline maximum DTI of 50.00% 3. Excellent mortgage payment history since inception on 09/2017 4. No public records

Cured

Credit

EG1

9/20/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593013

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.   The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3291

10/3/2019

Waived/Exception Granted

Compensating Factors: 1. 806 FICO scores, 166 points greater than program guideline minimum FICO scores of 640 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 20 months reserves,  15 months greater than program guideline 5 months reserves requirement (3 months for subject property plus 2 months for investment properties 4. No public records

Waived

Compliance

EG2

10/2/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593013

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3346

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 806 FICO scores, 166 points greater than program guideline minimum FICO scores of 640 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 20 months reserves,  15 months greater than program guideline 5 months reserves requirement (3 months for subject property plus 2 months for investment properties 4. No public records

Cured

Credit

EG1

10/2/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593013

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Exclude monthly obligation of $813.66 per month from Land loan paid by borrower's mother with 8 months of canceled checks (as 4 checks came from the borrower's business account - see LOE from mother) vs program requirement of a full 12 months of canceled checks from a third party evidencing payment to exclude liability from DTICompensating Factors:1. 806 FICO scores, 166 points greater than program guideline minimum FICO scores of 6402. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00%3. 20 months reserves,  15 months greater than program guideline 5 months reserves requirement (3 months for subject property plus 2 months for investment properties4. No public records

7000-3347

10/2/2019

Waived/Exception Granted

client exception granted with compensating factors

Compensating Factors: 1. 806 FICO scores, 166 points greater than program guideline minimum FICO scores of 640 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 20 months reserves,  15 months greater than program guideline 5 months reserves requirement (3 months for subject property plus 2 months for investment properties 4. No public records

Waived

Credit

EG2

10/2/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593013

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: DTI is 50.68% vs program maximum DTI of 50.00%Compensating Factors:1. 806 FICO scores, 166 points greater than program guideline minimum FICO scores of 6402. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00%3. 20 months reserves,  15 months greater than program guideline 5 months reserves requirement (3 months for subject property plus 2 months for investment properties4. No public records

7000-3349

10/2/2019

Waived/Exception Granted

client exception granted with compensating factors

Compensating Factors: 1. 806 FICO scores, 166 points greater than program guideline minimum FICO scores of 640 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 20 months reserves,  15 months greater than program guideline 5 months reserves requirement (3 months for subject property plus 2 months for investment properties 4. No public records

Waived

Credit

EG2

10/2/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593015

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing rate lock agreement

7000-3063

9/18/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 737 FICO Scores, 57 points greater than program guideline minimum FICO Scores of 680 2. 6 months reserves, 3 months greater than program guideline 3 months reserves requirement 3. 40.06% DTI, 2.94% less than program guideline maximum DTI of 43.00% 4. No public records

Cured

Credit

EG1

9/17/2019

Primary Residence

AZ

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG1

EG3

EG1

EG1

EG1

EG1

EG1

10/30/2019

430593016

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: DTI is 54.981% vs program guideline maximum DTI of 50.00%Compensating Factors:1. 720 FICO, 62 points greater than program guideline minimum FICO of 6402. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for the past 12 years4. No public records

7000-3023

9/13/2019

Waived/Exception Granted

Compensating Factors: 1. 720 FICO, 62 points greater than program guideline minimum FICO of 640 2. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for the past 12 years 4. No public records

Waived

Credit

EG2

9/13/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593016

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure (CD) in file dated XXXX do not match the Seller Paid fees on the XXXX Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-3001

9/16/2019

Waived/Exception Granted

Compensating Factors: 1. 720 FICO, 62 points greater than program guideline minimum FICO of 640 2. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for the past 12 years 4. No public records

Waived

Compliance

EG2

9/13/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593016

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-3002

9/16/2019

Waived/Exception Granted

Compensating Factors: 1. 720 FICO, 62 points greater than program guideline minimum FICO of 640 2. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for the past 12 years 4. No public records

Waived

Compliance

EG2

9/13/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593017

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3243

10/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00% 2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement 3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

Cured

Credit

EG1

9/28/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430593017

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Loan Amount is $xx,xxx.xx vs program minimum requirement of $100,000.00Compensating Factors:1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00%2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

7000-3244

10/4/2019

Waived/Exception Granted

Compensating Factors: 1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00% 2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement 3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

Waived

Credit

EG2

9/28/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430593017

XXXX

XXXX

XXXX

Property - Collateral

Missing Condo Budget, Condo Insurance, and evidence of Condo maintenance fees. // UPDATED 10/2/2019:  Received copy of master insurance policy only.. Per HOA questionnaire, a copy of the HOA annual budget and most recent HOA yearend financial statement are required - still need./// Update 10/4/2019 The HOA questionnaire is requiring that the annual budget and HOA year end  financial statement be provided.

7000-3245

10/7/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00% 2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement 3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

Cured

Property

EG1

9/28/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430593017

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing required signed 4506-T from both borrowers'

7000-3246

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00% 2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement 3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

Cured

Credit

EG1

9/28/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430593017

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Lender Credit was removed on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the lender credits that cannot decrease test. ( 12 CFR 1026.19(e)(3)(i) )The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i). The final sum of specificand non-specific lender credits ($0.00) does not exceed or equal the comparable sum of specific and non-specific lender credits($432.00).

7000-3234

10/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 10/02/2019: Received 09/10/2019 rate lock and COC.

Compensating Factors: 1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00% 2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement 3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

Cured

Compliance

EG1

9/28/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430593017

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing appraisal invoice to confirm Appraisal Fee of $575.00 as reflected on Final Closing Disclosure dated XXXX.

7000-3235

10/11/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/11/2019: Received PCCD, borrower letter, and proof of delivery. The final Alta Settlement Statement showed that the appraisal fee was paid POC, so no additional evidence of borrower reimbursement needed.

Compensating Factors: 1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00% 2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement 3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

Cured

Compliance

EG2

9/28/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430593017

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:   NC Fee Information From your Mortgage Broker for your Mortgage Loan a/k/a Mortgage Broker Application Disclosure.

7000-3236

10/1/2019

Waived/Exception Granted

Compensating Factors: 1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00% 2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement 3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

Waived

Compliance

EG2

9/28/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430593017

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3231

10/1/2019

Waived/Exception Granted

Compensating Factors: 1. 28.47% DTI, 14.53% less than program guideline maximum DTI of 43.00% 2. 314 months reserves, 311 months greater than program guideline 3 months reserves requirement 3. 60.00% LTV, 30% less than program guideline maximum DTI of 90.00%

Waived

Compliance

EG2

9/28/2019

Primary Residence

NC

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG3

EG1

10/30/2019

430593019

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. Need Post Consummation Closing Disclosure correcting the fees.  Closing Disclosure in file dated XXXX reflects Title Fees Paid to XXXX and listed in Section C and need to be moved to Section B per the Service Providers List.

7000-3159

9/26/2019

Waived/Exception Granted

Compensating Factors: 1. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 2. 41.96% DTI, 8.04% less than program guideline maximum DTI of 50.00% 3. 75.00% LTV, 10% less than program guideline maximum LTV of 85.00% 4. 662 FICO scores, 22 points greater than program guideline minimum FICO scores of 640

Waived

Compliance

EG2

9/24/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593019

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing lock confirmation

7000-3160

9/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 2. 41.96% DTI, 8.04% less than program guideline maximum DTI of 50.00% 3. 75.00% LTV, 10% less than program guideline maximum LTV of 85.00% 4. 662 FICO scores, 22 points greater than program guideline minimum FICO scores of 640

Cured

Credit

EG1

9/24/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593019

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing letter of explanation regarding canceled rent checks payment made by XXXX for the months of 07/2019, 06/2019, 01/2019, 12/2018, 09/2018, 08/2018, 07/2018, 06/2018, 05/2018, 04/2018, 03/2018, 02/2018 and 12/2017  ///  UPDATED 9/27/2019 rent checks written from XXXX were provided to support the VOR used to verify the borrower's residence history. Missing the LOE regarding why the housing payments were made by a 3rd party and not by the borrower.

7000-3161

10/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 2. 41.96% DTI, 8.04% less than program guideline maximum DTI of 50.00% 3. 75.00% LTV, 10% less than program guideline maximum LTV of 85.00% 4. 662 FICO scores, 22 points greater than program guideline minimum FICO scores of 640

Cured

Credit

EG1

9/24/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593019

XXXX

XXXX

XXXX

Credit - Income and Assets

Missing verification of self employment for a minimum of 2 continuous years using Business License, CPA Letter or Regulatory Agency for XXXX

7000-3162

10/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 2. 41.96% DTI, 8.04% less than program guideline maximum DTI of 50.00% 3. 75.00% LTV, 10% less than program guideline maximum LTV of 85.00% 4. 662 FICO scores, 22 points greater than program guideline minimum FICO scores of 640

Cured

Credit

EG1

9/24/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593019

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Non-arm's length transaction.  Missing 2nd appraisal.  Borrower is the tenant of the property being purchased.  Tenant/landlord is considered non-arm's length transaction - Existing lease between the tenant and the landlord.  //  UPDATED 9/27/2019: Still missing 2nd appraisal.  Borrower is a tenant of property being purchased.  The contractual agreement between landlord and tenant constitutes a non arm's length transaction.

7000-3184

9/27/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Purchase agreement $xxxx vs appraised value $xxxx - no seller concessions.

Compensating Factors: 1. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 2. 41.96% DTI, 8.04% less than program guideline maximum DTI of 50.00% 3. 75.00% LTV, 10% less than program guideline maximum LTV of 85.00% 4. 662 FICO scores, 22 points greater than program guideline minimum FICO scores of 640

Cured

Credit

EG1

9/24/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593019

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3155

9/26/2019

Waived/Exception Granted

Compensating Factors: 1. 17 months reserves, 14 months greater than program guideline 3 months reserves requirement 2. 41.96% DTI, 8.04% less than program guideline maximum DTI of 50.00% 3. 75.00% LTV, 10% less than program guideline maximum LTV of 85.00% 4. 662 FICO scores, 22 points greater than program guideline minimum FICO scores of 640

Waived

Compliance

EG2

9/24/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593020

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3070

9/23/2019

Waived/Exception Granted

Compensating Factors: 1. 695 FICO Scores, 15 points greater than program guideline minimum FICO scores of 680 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 2 years 4. No public records

Waived

Compliance

EG2

9/19/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593020

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  TX Mortgage Company Disclosure.

7000-3073

9/23/2019

Waived/Exception Granted

Compensating Factors: 1. 695 FICO Scores, 15 points greater than program guideline minimum FICO scores of 680 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 2 years 4. No public records

Waived

Compliance

EG2

9/19/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593020

XXXX

XXXX

XXXX

Credit - Income and Assets

The recalculated income of $5,236.67 resulted in a DTI of 43.91% which exceeded the program maximum DTI of 43.00%. The loan file is missing the October 2018 business bank statements from XXXX account ending in xxxx. Loan is subject to income recalculation

7000-3089

9/24/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 695 FICO Scores, 15 points greater than program guideline minimum FICO scores of 680 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. Owner of the same business for 2 years 4. No public records

Cured

Credit

EG1

9/19/2019

Primary Residence

TX

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593021

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3216

10/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 16 months reserves, 13 months greater than program guideline 3 reserves requirement 2. 696 FICO Scores, 16 points greater than program guideline minimum FICO scores of 680 3. No public records

Cured

Credit

EG1

9/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593021

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing evidence that the borrower's revolving account with XXXX xxxxxx has been paid off and not paid down. The payoff statement reflects a balance of $XXXX and the Final HUD-1 only reflects a disbursement of $3,188.93 which would not be sufficient to meet the amount reflected on the payoff statement. Subject to recalculation of the qualifying debt to income ratios.  // UDPATED 10/1/2019 : Closing instructions also reflect payoff to XXXX of $6638 and payoff to XXXX of $3188.93.  Missing escrow disbursement sheet reflecting final payoff amounts to XXXX and XXXX.

7000-3220

10/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 16 months reserves, 13 months greater than program guideline 3 reserves requirement 2. 696 FICO Scores, 16 points greater than program guideline minimum FICO scores of 680 3. No public records

Cured

Credit

EG1

9/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593021

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.   The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3197

9/30/2019

Waived/Exception Granted

Compensating Factors: 1. 16 months reserves, 13 months greater than program guideline 3 reserves requirement 2. 696 FICO Scores, 16 points greater than program guideline minimum FICO scores of 680 3. No public records

Waived

Compliance

EG2

9/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593021

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-3199

9/30/2019

Waived/Exception Granted

Compensating Factors: 1. 16 months reserves, 13 months greater than program guideline 3 reserves requirement 2. 696 FICO Scores, 16 points greater than program guideline minimum FICO scores of 680 3. No public records

Waived

Compliance

EG2

9/26/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593023

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure: The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3242

10/2/2019

Waived/Exception Granted

Compensating Factors: 1. 32.98% DTI, 10.02% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 4 years 3. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

9/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593023

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing a copy of the borrower's foreign  passport as required by the guidelines. The 1003 loan application indicates the borrower is not a US citizen or a permanent residence alien.

7000-3250

10/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

VISA E2 expiration date 6/28/2021

Compensating Factors: 1. 32.98% DTI, 10.02% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 4 years 3. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

9/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593023

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing CPA letter regarding use of business assets for earnest money deposit and closing costs in XXXX Business Checking Acct #xxxx and the impact, if any, it would have on the borrower's business.

7000-3238

10/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Guideline amendment 7/8/2019

Compensating Factors: 1. 32.98% DTI, 10.02% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 4 years 3. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

9/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593023

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3233

10/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 32.98% DTI, 10.02% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 4 years 3. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

9/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593023

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-3218

10/1/2019

Waived/Exception Granted

Compensating Factors: 1. 32.98% DTI, 10.02% less than program guideline maximum DTI of 43.00% 2. Owner of the same business for 4 years 3. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

9/27/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593025

XXXX

XXXX

XXXX

Property - Collateral

Missing Condo Budget, Condo Insurance, and evidence of Condo maintenance fees.

7000-3141

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 651 FICO Scores, 11 points greater than program guideline minimum FICO scores of 640 4. Borrower has been self employed as xxxx for the past 6 years

Cured

Property

EG1

9/23/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430593025

XXXX

XXXX

XXXX

Credit - Credit

Missing evidence of rent paid for the months of 02/2019, 10/2018, 09/2018 and 08/2018 for property located at XXXX

7000-3142

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 651 FICO Scores, 11 points greater than program guideline minimum FICO scores of 640 4. Borrower has been self employed as xxxx for the past 6 years

Cured

Credit

EG1

9/23/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430593025

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Excluded XXXX payment of $1,955.00 per month on borrower's credit report with 10 months' evidence borrower's business has been paying the loan (due to the fact that its inception date was also 10 months ago in 10/2018) vs program requirement of a full most recent 12 months' evidence of third party paying a debt to exclude from DTICompensating Factors:1. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00%3. 651 FICO Scores, 11 points greater than program guideline minimum FICO scores of 6404. Borrower has been self employed as xxxx for the past 6 years

7000-3143

9/23/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 651 FICO Scores, 11 points greater than program guideline minimum FICO scores of 640 4. Borrower has been self employed as xxxx for the past 6 years

Waived

Credit

EG2

9/23/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430593025

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Lock Confirmation

7000-3145

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 651 FICO Scores, 11 points greater than program guideline minimum FICO scores of 640 4. Borrower has been self employed as xxxx for the past 6 years

Cured

Credit

EG1

9/23/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430593025

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3110

9/25/2019

Waived/Exception Granted

Compensating Factors: 1. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 651 FICO Scores, 11 points greater than program guideline minimum FICO scores of 640 4. Borrower has been self employed as xxxx for the past 6 years

Waived

Compliance

EG2

9/23/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430593025

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  IL Loan Brokerage Agreement and IL Loan Brokerage Disclosure Statement.

7000-3111

9/25/2019

Waived/Exception Granted

Compensating Factors: 1. 23 months reserves, 20 months greater than program guideline 3 months reserves requirement 2. 80.00% LTV, 5% less than program guideline maximum LTV of 85.00% 3. 651 FICO Scores, 11 points greater than program guideline minimum FICO scores of 640 4. Borrower has been self employed as xxxx for the past 6 years

Waived

Compliance

EG2

9/23/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG3

EG1

10/30/2019

430593027

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Lock Confirmation.

7000-3343

10/7/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 69.837% LTV; 15.163% below 85% maximum 2. Mortgage history is 0x30 for 12 months   3. No public records 4. DTI ratio of 32.91%; 17.09% less than 50% maximum

Cured

Credit

EG1

10/2/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593027

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception for program requirement of 24 months of self-employment. Borrower has been self-employed for the past 22 months since 10/04/2017.Compensating Factors:1. 69.837% LTV; 15.163% below 85% maximum2. Mortgage history is 0x30 for 12 months  3. No public records4. DTI ratio of 32.91%; 17.09% less than 50% maximum

7000-3344

10/2/2019

Waived/Exception Granted

Client elects to waive guideline requirement with compensating factors.

Compensating Factors: 1. 69.837% LTV; 15.163% below 85% maximum 2. Mortgage history is 0x30 for 12 months   3. No public records 4. DTI ratio of 32.91%; 17.09% less than 50% maximum

Waived

Credit

EG2

10/2/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593027

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Closing Disclosure in file dated XXXX reflects inaccurate interest from and disbursement dates.  Interest from date reflects XXX and Disbursement date reflects XXXX, however, consummation occurred XXXX.  Need Post Consummation CD with explanation letter to borrower and proof of method of delivery to borrower reflecting accurate interest from and disbursement dates.

7000-3306

10/8/2019

Waived/Exception Granted

Compensating Factors: 1. 69.837% LTV; 15.163% below 85% maximum 2. Mortgage history is 0x30 for 12 months   3. No public records 4. DTI ratio of 32.91%; 17.09% less than 50% maximum

Waived

Compliance

EG2

10/2/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593027

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

$175.00 Appraisal Fee for 1004D completion report paid prior to close missing from XXXX final Closing Disclosure, despite invoice in file. Need Post Consummation Closing Disclosure with borrower letter and proof of delivery, listing the $175.00 Appraisal Fee for 1004D paid prior to close. Note: This will result in a TRID charge that cannot increase violation.

7000-3321

10/10/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/10/2019: Received PCCD, reimbursement check, borrower letter, and proof of delivery.

Compensating Factors: 1. 69.837% LTV; 15.163% below 85% maximum 2. Mortgage history is 0x30 for 12 months   3. No public records 4. DTI ratio of 32.91%; 17.09% less than 50% maximum

Cured

Compliance

EG2

10/2/2019

Primary Residence

CA

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593029

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation /// UPDATED 10/1/2019: Received lock confirmation for 7/1 ARM product that does not reflect the Margin.  Missing corrected Lock confirmation.

7000-3206

10/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00% 2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for the past 4 years 4. No public records

Cured

Credit

EG1

9/26/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593029

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client Approved Exception: Approved exception in the file to allow funds for the down payment ($5,000.00 EMD) and closing costs to come  from the borrower's business account (borrower has no personal bank account) vs the program requirement that if funds in a business bank or brokerage account have not been transferred to the borrower's personal accounts, such funds may not be included in Down Payment and Closing CostsCompensating Factors:1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00%2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 6403. Owner of the same business for the past 4 years4. No public records

7000-3207

9/26/2019

Waived/Exception Granted

Compensating Factors: 1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00% 2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for the past 4 years 4. No public records

Waived

Credit

EG2

9/26/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593029

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client Approved Exception: Approved exception in file to allow the collection account with XXXX #3100 for $XXXX (child support) and a charge off from XXXX #xxxx for $XXXX (Auto) to remain open vs program requirement that all non-medical collection accounts and charge-offs exceeding $1,000.00 which are not in dispute (except collection accounts and charge offs no longer enforceable due to applicable state statute of limitations), must be paid in full prior to or at the time of a loan's funding by originating lenderCompensating Factors:1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00%2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 6403. Owner of the same business for the past 4 years4. No public records

7000-3208

9/26/2019

Waived/Exception Granted

Compensating Factors: 1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00% 2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for the past 4 years 4. No public records

Waived

Credit

EG2

9/26/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593029

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client Approved Exception: Approved exception as the borrower paid 6 months past due child support up front. All past due payments were made  at the same time with 6 separate receipts vs program requirement history 6 monthly payments of child support per bottom of approved revision #2Compensating Factors:1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00%2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 6403. Owner of the same business for the past 4 years4. No public records

7000-3209

9/26/2019

Waived/Exception Granted

Compensating Factors: 1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00% 2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for the past 4 years 4. No public records

Waived

Credit

EG2

9/26/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593029

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing a signed letter of explanation and the source of the following large deposit into borrower's XXXX account ending in xxxxxx on 07/18/2019 in the amount of $61,609.00. The loan is subject to income and assets recalculation  /// UPDATED 10/1/2019: Deducted large deposit from qualifying income results in increased DTI to 52.33% and exceeds 50.00% guideline maximum.

7000-3210

10/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

recalculated worksheet completed

Compensating Factors: 1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00% 2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for the past 4 years 4. No public records

Cured

Credit

EG1

9/26/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593029

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. Lender over disclosed ETIA/ non-escrow collection on Final CD dated XXXX. Total ETIA and monthly non-escrow totals should be $1057.31 not $1067.84. Hazard Insurance premium of $379.92 monthly is $31.66.  For Taxes, used Tax Information Sheet, shows annual Property tax amount of $5786.16  monthly $482.18,  Adding these three  monthly  amounts equals $1057.31. NEED PCCD correcting non-escrow property costs in year 1/ETIA, along with letter of explanation and proof of delivery to borrower.

7000-3185

10/4/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/04/2019: Received PCCD, Seller CD, borrower letter, and proof of delivery.

Compensating Factors: 1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00% 2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for the past 4 years 4. No public records

Cured

Compliance

EG2

9/26/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593029

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures: Missing the Anti Steering Option Disclosure.

7000-3186

9/30/2019

Waived/Exception Granted

Compensating Factors: 1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00% 2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for the past 4 years 4. No public records

Waived

Compliance

EG2

9/26/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593029

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following required Federal and/or State Disclosures: Missing the Illinois Loan Brokerage agreement and Broker Disclosure statement.

7000-3187

10/2/2019

Waived/Exception Granted

Compensating Factors: 1. 36.24% DTI, 13.76% less than program guideline maximum DTI of 50.00% 2. 709 FICO scores, 69 points greater than program guideline minimum FICO scores of 640 3. Owner of the same business for the past 4 years 4. No public records

Waived

Compliance

EG2

9/26/2019

Primary Residence

IL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593032

XXXX

XXXX

XXXX

Credit - Credit

Missing verification of mortgage history for  property  located at XXXX not to exceed 1X30 in the past 12 months. The mortgage statement indicates that the non-borrowing spouse is the lien holder. \\\Update 9/20/2019 The mortgage history with XXXX provided  reflects 2x30 in the past 12 months which exceeds the maximum 1x30x12 allowed by the lender guidelines. The pay history reflects the borrower was 30 days late in 8/2018 and 2/2019. Missing documentation to support the borrower's current 12 month housing history, if borrower is responsible for mortgage history provided then exceeds housing history guidelines.

7000-3079

9/25/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 9 years 3. No public records 4. 686 Fico is 6 points greater than program requirement of 680

Cured

Credit

EG1

9/18/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593032

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing final signed HUD proof of sale for departing residence located at XXXX. Loan is subject to recalculation. \\\\Update 9/20/2019 The borrower's reserves are sufficient to meet guideline requirement if borrower has retained property.

7000-3081

9/20/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 9 years 3. No public records 4. 686 Fico is 6 points greater than program requirement of 680

Cured

Credit

EG1

9/18/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593032

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Lock Confirmation to verify terms of subject transaction.

7000-3082

9/23/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 9 years 3. No public records 4. 686 Fico is 6 points greater than program requirement of 680

Cured

Credit

EG1

9/18/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593032

XXXX

XXXX

XXXX

Credit - Income and Assets

The recalculated income of $x,xxx.xx resulted in a DTI of 51.20% which exceeded the loan program guideline maximum DTI of 50.00%. The lender understated the monthly HOA dues by $307.67 and did not included a revolving account from XXXX account ending in xxxx with a balance of $3,955.00 and monthly payment of $88.00 as well as a revolving account with XXXX account ending in xxxx with a balance of $105.00 and monthly payment of $25.00. In addition, the Lender overstated the borrower's total deposits on the August 2018 statement from XXXX account ending in xxxx by $14,400.00. The August 2018 statement reflected total deposits of $17,253.13

7000-3083

10/23/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 9 years 3. No public records 4. 686 Fico is 6 points greater than program requirement of 680

Cured

Credit

EG1

9/18/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593032

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3058

9/19/2019

Waived/Exception Granted

Compensating Factors: 1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 9 years 3. No public records 4. 686 Fico is 6 points greater than program requirement of 680

Waived

Compliance

EG2

9/18/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593032

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Points added on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $1,572.39.

7000-3060

9/24/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 09/24/2019: Received 08/30/2019 COC indicating broker compensation changed. Client notes indicated interest rate was reduced from 7.385% to 7.26%.

Compensating Factors: 1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 9 years 3. No public records 4. 686 Fico is 6 points greater than program requirement of 680

Cured

Compliance

EG1

9/18/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593032

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  Lender under disclosed ETIA/non-escrow collection on Final CD dated XXXX. Total ETIA  total should be $926.34 not $618.67.  Hazard Insurance premium of $1,370.00 monthly is $114.17.  For Taxes, used Tax Information Sheet, shows annual Property tax amount of $5,054.04  monthly $421.17, HOA is 391.00 monthly based on the appraisal in file.  Adding these amounts equals $926.34. NEED PCCD correcting ETIA and non-escrow property costs in year 1, along with letter of explanation and proof of method of delivery to borrower.

7000-3061

9/25/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

Received PCCD dated 9/24/19 correcting the ETIA/ non escrow property costs in year 1 along with LOE and POD

Compensating Factors: 1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 9 years 3. No public records 4. 686 Fico is 6 points greater than program requirement of 680

Cured

Compliance

EG2

9/18/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593032

XXXX

XXXX

XXXX

Credit - Income and Assets

Client exception approved provided. Client exception provided as recalculated DTI is 51.20%  vs program maximum of 50.00%Compensating Factors:1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement2. Owner of the same business for 9 years3. No public records4. 686 Fico is 6 points greater than program requirement of 680

7000-3700

10/23/2019

Waived/Exception Granted

Compensating Factors: 1. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 2. Owner of the same business for 9 years 3. No public records 4. 686 Fico is 6 points greater than program requirement of 680

Waived

Credit

EG2

9/18/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593033

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure dated XXXX is Missing All of the Seller Paid fees reflected on the Sellers Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3275

10/4/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/04/2019: Received PCCD with borrower letter and proof of delivery.

Compensating Factors: 1. 802 FICO scores, 162 points greater than program guideline minimum FICO scores of 640 2. Owner of the same business for the past 18 years and 8 months 3. 40.46% DTI, 9.54% less than program guideline maximum DTI of 50.00% 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593033

XXXX

XXXX

XXXX

Credit - Credit

The loan file is missing documentation to evidence that the judgment filed on 09/2018 with XXXX with a balance of $XXXX has been satisfied

7000-3327

10/16/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

The client provided an excpetion for the open collection account to remain open and not paid off as required by the guidelines.

Compensating Factors: 1. 802 FICO scores, 162 points greater than program guideline minimum FICO scores of 640 2. Owner of the same business for the past 18 years and 8 months 3. 40.46% DTI, 9.54% less than program guideline maximum DTI of 50.00% 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593033

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID zero fee tolerance.  Survey Fee ($50) and Endorsement Fee ($10) increased on Closing Disclosure dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $60.00.

7000-3280

10/4/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/04/2019: Received PCCD with borrower letter, reimbursement check, and proof of delivery.

Compensating Factors: 1. 802 FICO scores, 162 points greater than program guideline minimum FICO scores of 640 2. Owner of the same business for the past 18 years and 8 months 3. 40.46% DTI, 9.54% less than program guideline maximum DTI of 50.00% 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Compliance

EG2

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593033

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-3281

10/3/2019

Waived/Exception Granted

Compensating Factors: 1. 802 FICO scores, 162 points greater than program guideline minimum FICO scores of 640 2. Owner of the same business for the past 18 years and 8 months 3. 40.46% DTI, 9.54% less than program guideline maximum DTI of 50.00% 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593033

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing the Rate Lock Confirmation for the subject property.

7000-3322

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 802 FICO scores, 162 points greater than program guideline minimum FICO scores of 640 2. Owner of the same business for the past 18 years and 8 months 3. 40.46% DTI, 9.54% less than program guideline maximum DTI of 50.00% 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593033

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Client approved exception for leaving an open judgment vs program requirement that all open judgment be satisfied. Compensating Factors:1. 802 FICO scores, 162 points greater than program guideline minimum FICO scores of 6402. Owner of the same business for the past 18 years and 8 months3. 40.46% DTI, 9.54% less than program guideline maximum DTI of 50.00%4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

7000-3618

10/16/2019

Waived/Exception Granted

Compensating Factors: 1. 802 FICO scores, 162 points greater than program guideline minimum FICO scores of 640 2. Owner of the same business for the past 18 years and 8 months 3. 40.46% DTI, 9.54% less than program guideline maximum DTI of 50.00% 4. 5 months reserves, 2 months greater than program guideline 3 months reserves requirement

Waived

Credit

EG2

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593037

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE 10/04/2019: Received 09/05/2019 Change of Circumstance; however, it was not valid, due to the following: Change of Circumstance states it was for second appraisal fee of $475.00 due to "2nd appraisal requirement." However, the Seller approval didn't specify a second appraisal was required, and the subject loan amount and loan program would not require a second appraisal per Lender Guidelines. This loan failed TRID zero fee tolerance.  Second Appraisal added on Loan Estimate dated XXXX without a Valid Change of Circumstance results in the below TRID tolerance violation.Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $475.00.

7000-3283

10/8/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

10/08/2019 Received Lender's Manual Approval reflecting 2nd Appraisal required as loan is HPML.

Compensating Factors: 1. 36.25% DTI, 13.75% less than program guideline maximum DTI of 50.00% 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 728 FICO scores, 88 points greater than program guideline minimum FICO scores of 640

Cured

Compliance

EG1

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593037

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

This loan failed TRID 10% fee tolerance. Title Endorsement added on Closing Disclosure dated XXXX without a valid Change of Circumstance results in the below TRID tolerance violation.integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that in total cannot increase more than 10% test. (12 CFR 1026.19(e)(3)(ii))The loan contains third-party services that the consumer was permitted to shop for and the charges exceed the good faithtolerance according to 1026.19(e)(3)(ii). The final charges that in total cannot increase more than 10% ($398.15) exceed thecomparable charges ($301.00) by more than 10%.  Total amount $67.05

7000-3284

10/10/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/10/2019: Received PCCD, reimbursement check, borrower letter, and proof of delivery.

Compensating Factors: 1. 36.25% DTI, 13.75% less than program guideline maximum DTI of 50.00% 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 728 FICO scores, 88 points greater than program guideline minimum FICO scores of 640

Cured

Compliance

EG2

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593037

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Lender over disclosed ETIA on Final CD dated XXXX.  Total ETIA and monthly escrow totals should be $351.62, not $368.81. Hazard Insurance premium of $590.00 monthly is $49.17.  For Taxes, used Tax Information Sheet, shows annual Property tax amount of $295.68  monthly $24.64.  HOA per rider in Purchase Contract reflects 277.81 per month.  Escrow is correct, however, the ETIA should be $351.62. NEED PCCD correcting ETIA and non-escrow property costs in year1, along with letter of explanation and proof of delivery to borrower.

7000-3285

10/10/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/10/2019: Received PCCD, borrower letter, and proof of delivery.

Compensating Factors: 1. 36.25% DTI, 13.75% less than program guideline maximum DTI of 50.00% 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 728 FICO scores, 88 points greater than program guideline minimum FICO scores of 640

Cured

Compliance

EG2

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593037

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3328

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 36.25% DTI, 13.75% less than program guideline maximum DTI of 50.00% 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 728 FICO scores, 88 points greater than program guideline minimum FICO scores of 640

Cured

Credit

EG1

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593037

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing documentation to evidence the payment of the 4/2019 rental obligation or documentation from the landlord that  it was not required to be paid.

7000-3351

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 36.25% DTI, 13.75% less than program guideline maximum DTI of 50.00% 2. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 3. 728 FICO scores, 88 points greater than program guideline minimum FICO scores of 640

Cured

Credit

EG1

10/1/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593038

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Final Settlement Statement in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3127

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 640 2. 45.66% DTI, 4.34% less than program guideline maximum DTI of 50.00% 3. Owner of the same business for 10 years

Waived

Compliance

EG2

9/23/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593038

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

UPDATE:  09/26/2019 Received request for further explanation of Tolerance Violation.  On 08/28/2019 a Recording Service Fee was added to Section "B" payable to XXXX.  This fee is being considered in the Zero Tolerance bucket as the Settlement Service Provider's List only reflects XXXX.  Either a Change of Circumstance for the addition of this fee needs to be added, or Fees payable to XXXX should be moved to Section "C" as Borrower's Provider.  If Fees are actually Borrower's choice/provider, Need Post Consummation Closing Disclosure with explanation letter to borrower and proof of method of delivery to borrower.This loan failed TRID zero fee tolerance.  Recording Service Fee was added on Closing Disclosure dated 08/28/2019 without a Valid Change of Circumstance. results in the below TRID tolerance violation. Integrated Disclosures Tolerance & Reimbursement Provisions - XXXX - 1This loan failed the charges that cannot increase test. (12 CFR 1026.19(e)(3)(i))The loan contains charges that exceed the good faith determination according to 1026.19(e)(3)(i).One or more of the final charges exceed the comparable amount. Your total tolerance violation is $190.00.This loan failed the reimbursement amount test. (12 CFR 1026.19(f)(2)(v))Amounts paid by the consumer exceed the permitted tolerances and the provided reimbursement amount of $150.00, is notsufficient to reimburse the consumer the amount by which the tolerances were exceeded, $190.00.After applying the $150.00 Lender Credit, the remaining reimbursement violation is $40.00.

7000-3128

9/30/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

Received PCCD, LOE and POD moving title fees down to section C. This removed the TRID tolerance violation.

Compensating Factors: 1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 640 2. 45.66% DTI, 4.34% less than program guideline maximum DTI of 50.00% 3. Owner of the same business for 10 years

Cured

Compliance

EG2

9/23/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593038

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  MD Application Disclosure and MD Mortgage Broker Agreement.

7000-3129

9/24/2019

Waived/Exception Granted

Compensating Factors: 1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 640 2. 45.66% DTI, 4.34% less than program guideline maximum DTI of 50.00% 3. Owner of the same business for 10 years

Waived

Compliance

EG2

9/23/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593038

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

//UPDATE:  09/26/2019 Received only the 2 page Legal Description.  NEED full copy of the Deed of Trust inclusive of the 2 page Legal Description.Document not properly executed or dated: The Deed of Trust is missing page 2 of the legal description.  Need complete, fully executed copy of Deed of Trust inclusive of all pages of the legal description.

7000-3132

9/30/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

received copy of full DOT with Exb A - Legal

Compensating Factors: 1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 640 2. 45.66% DTI, 4.34% less than program guideline maximum DTI of 50.00% 3. Owner of the same business for 10 years

Cured

Compliance

EG1

9/23/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593038

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing updated credit report with updated FICO scores. The credit report in file dated XXXX expired on xx/xx/xx which is before the initial application dated XXXX. /// UDPATED 9/26/2019:  The credit report received does not contain credit scores.  The original credit report containing scores is expired.  Missing updated credit report with credit scores.

7000-3148

10/1/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 640 2. 45.66% DTI, 4.34% less than program guideline maximum DTI of 50.00% 3. Owner of the same business for 10 years

Cured

Credit

EG1

9/23/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593038

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: LTV is 80% vs program maximum of 70.00%Compensating Factors:1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 6402. 44.61% DTI, 5.39% less than program guideline maximum DTI of 50.00%3. Owner of the same business for 10 years

7000-3149

9/23/2019

Waived/Exception Granted

client granted exception with compensating factors.

Compensating Factors: 1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 640 2. 45.66% DTI, 4.34% less than program guideline maximum DTI of 50.00% 3. Owner of the same business for 10 years

Waived

Credit

EG2

9/23/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593038

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Allow Condotel project that includes a building with timesharesCompensating Factors:1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 6402. 44.61% DTI, 5.39% less than program guideline maximum DTI of 50.00%3. Owner of the same business for 10 years

7000-3150

9/23/2019

Waived/Exception Granted

Client granted exception with compensating factors

Compensating Factors: 1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 640 2. 45.66% DTI, 4.34% less than program guideline maximum DTI of 50.00% 3. Owner of the same business for 10 years

Waived

Credit

EG2

9/23/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593038

XXXX

XXXX

XXXX

Credit - Credit

Missing Verification of Rent from 2018 to present for the borrower's current residence located at XXXX//Updated 09/25/2019 Verification of Rent provided covers the period from 2012 to 2018 but does not cover the most recent 12 month period.

7000-3146

10/10/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Received updated 1003 - prior res xxxx; cur res xxxx.

Compensating Factors: 1. 770 FICO Scores, 130 points greater than program guideline minimum FICO of 640 2. 45.66% DTI, 4.34% less than program guideline maximum DTI of 50.00% 3. Owner of the same business for 10 years

Cured

Credit

EG1

9/23/2019

Primary Residence

MD

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG3

EG2

EG1

EG1

10/30/2019

430593041

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3311

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 720 FICO scores, 80 points greater than program guideline minimum FICO scores of 640 2. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement (3 months for primary residence and 2 months for 2 investment properties) 3. No public records for the primary borrower’s

Cured

Credit

EG1

10/1/2019

Primary Residence

OR

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593041

XXXX

XXXX

XXXX

Credit - Credit

The loan file is missing a credit report for the co-borrower. Subject to the recalculation of the qualifying debt to income ratio.

7000-3314

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 720 FICO scores, 80 points greater than program guideline minimum FICO scores of 640 2. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement (3 months for primary residence and 2 months for 2 investment properties) 3. No public records for the primary borrower’s

Cured

Credit

EG1

10/1/2019

Primary Residence

OR

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593041

XXXX

XXXX

XXXX

Credit - Credit

The loan file is missing  the most recent 12 month rental rating for the co-borrower for their current residence located at XXXX. Maximum 1x30 for the past 12 months.

7000-3315

10/11/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 720 FICO scores, 80 points greater than program guideline minimum FICO scores of 640 2. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement (3 months for primary residence and 2 months for 2 investment properties) 3. No public records for the primary borrower’s

Cured

Credit

EG1

10/1/2019

Primary Residence

OR

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593041

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.   Loan Estimate in file dated XXXX is Missing Pages 1 and 2.  Unable to complete Regulatory Compliance and TRID monitoring.

7000-3273

10/9/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

//UPDATE 10/09/2019: Received 08/29/2019 LE - data points reconcile with the LE portion that was wet-signed xx/xx/xxxx.

Compensating Factors: 1. 720 FICO scores, 80 points greater than program guideline minimum FICO scores of 640 2. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement (3 months for primary residence and 2 months for 2 investment properties) 3. No public records for the primary borrower’s

Cured

Compliance

EG1

10/1/2019

Primary Residence

OR

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593041

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-3274

10/3/2019

Waived/Exception Granted

Compensating Factors: 1. 720 FICO scores, 80 points greater than program guideline minimum FICO scores of 640 2. 8 months reserves, 3 months greater than program guideline 5 months reserves requirement (3 months for primary residence and 2 months for 2 investment properties) 3. No public records for the primary borrower’s

Waived

Compliance

EG2

10/1/2019

Primary Residence

OR

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593042

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Missing the following Federal and/or State specific disclosures:  Loan Options Disclosure/Anti-Steering Options Disclosure.

7000-3223

10/1/2019

Waived/Exception Granted

Compensating Factors: 1. 39.32% DTI, 10.68% less than program guideline maximum DTI of 50.00% 2. 766 FICO scores, 46 points greater than program guideline minimum FICO scores of 720 3. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 4. No public records

Waived

Compliance

EG2

9/28/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593042

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation // UPDATED 10/2/2019: Received rate lock, however, the loan amount is greater than the amount on the Note.  Missing corrected Rate Lock agreement to match final loan terms.

7000-3247

10/3/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 39.32% DTI, 10.68% less than program guideline maximum DTI of 50.00% 2. 766 FICO scores, 46 points greater than program guideline minimum FICO scores of 720 3. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 4. No public records

Cured

Credit

EG1

9/28/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593042

XXXX

XXXX

XXXX

Credit - Credit

Missing signed letter from XXXX indicating that the borrower's lives rent free since 12/2013 for departing residence located at XXXX

7000-3249

10/2/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 39.32% DTI, 10.68% less than program guideline maximum DTI of 50.00% 2. 766 FICO scores, 46 points greater than program guideline minimum FICO scores of 720 3. 7 months reserves, 4 months greater than program guideline 3 months reserves requirement 4. No public records

Cured

Credit

EG1

9/28/2019

Second Home

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG2

EG2

EG1

EG1

10/30/2019

430593044

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3331

10/8/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 793 FICO scores, 113 points greater than program guideline minimum FICO scores of 680 2. Owner of the same business for the past 34 years 3. 39.01% DTI, 3.99% less than program guideline maximum DTI of 43.00%

Cured

Credit

EG1

10/2/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593044

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing the rental rating for the borrower's current residence for 8/2018 and 12/2018. Maximum 1x30. Missing documentation to evidence the 8/2018 and 12/2018 rental payments did not exceed the guideline maximum of 1x30 for 12 months.

7000-3357

10/8/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 793 FICO scores, 113 points greater than program guideline minimum FICO scores of 680 2. Owner of the same business for the past 34 years 3. 39.01% DTI, 3.99% less than program guideline maximum DTI of 43.00%

Cured

Credit

EG1

10/2/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593044

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

Exhibit "A" attached to the Mortgage in file dated XXXX does not match the legal description reflected on the preliminary title report. Need a copy of Mortgage inclusive of correct Legal Description.

7000-3279

10/8/2019

Compliance conditions cured by satisfactory remediation docs/re-disclosures

//UPDATE 10/08/2019: Received recorded mortgage with legal description and riders.

Compensating Factors: 1. 793 FICO scores, 113 points greater than program guideline minimum FICO scores of 680 2. Owner of the same business for the past 34 years 3. 39.01% DTI, 3.99% less than program guideline maximum DTI of 43.00%

Cured

Compliance

EG2

10/2/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593044

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure.  The Closing Disclosure (CD) in file dated XXXX is missing all of the Seller Paid fees according to the Seller's Closing Disclosure in file.  Need Post Consummation Closing Disclosure with letter to borrower and proof of method of delivery reflecting all Seller Paid fees in Seller-Paid column of Borrower's CD.

7000-3277

10/4/2019

Waived/Exception Granted

Compensating Factors: 1. 793 FICO scores, 113 points greater than program guideline minimum FICO scores of 680 2. Owner of the same business for the past 34 years 3. 39.01% DTI, 3.99% less than program guideline maximum DTI of 43.00%

Waived

Compliance

EG2

10/2/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG1

EG3

EG2

EG1

EG1

10/30/2019

430593045

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Missing Rate Lock Confirmation

7000-3336

10/4/2019

Credit condition cleared, Compliance condition cleared (does not include compliance cures)

Compensating Factors: 1. 728 FICO scores, 48 points greater than program guideline minimum FICO scores of 680 2. Excellent mortgage payment history since inception 08/2016 3. No public records 4. 4 months reserves, 1 month greater than program guideline 3 months reserves requirement

Cured

Credit

EG1

10/2/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593045

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: Borrower's company, XXXX has been in existence since 06/13/2018 (14 months) vs program requirement that at least one borrower's must have been continually self-employed for the 2 yearsCompensating Factors:1. 728 FICO scores, 48 points greater than program guideline minimum FICO scores of 6802. Excellent mortgage payment history since inception 08/20163. No public records4. 4 months reserves, 1 month greater than program guideline 3 months reserves requirement

7000-3337

10/2/2019

Waived/Exception Granted

client exception approval granted with compensating factors.

Compensating Factors: 1. 728 FICO scores, 48 points greater than program guideline minimum FICO scores of 680 2. Excellent mortgage payment history since inception 08/2016 3. No public records 4. 4 months reserves, 1 month greater than program guideline 3 months reserves requirement

Waived

Credit

EG2

10/2/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593045

XXXX

XXXX

XXXX

Credit - General Underwriting Guideline Violation

Seller Approved Exception: DTI is 46.625% vs program guideline maximum DTI of 43.00%Compensating Factors:1. 728 FICO scores, 48 points greater than program guideline minimum FICO scores of 6802. Excellent mortgage payment history since inception 08/20163. No public records4. 4 months reserves, 1 month greater than program guideline 3 months reserves requirement

7000-3338

10/2/2019

Waived/Exception Granted

client exception approval granted with compensating factors.

Compensating Factors: 1. 728 FICO scores, 48 points greater than program guideline minimum FICO scores of 680 2. Excellent mortgage payment history since inception 08/2016 3. No public records 4. 4 months reserves, 1 month greater than program guideline 3 months reserves requirement

Waived

Credit

EG2

10/2/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

10/30/2019

430593045

XXXX

XXXX

XXXX

Compliance - Regulatory Compliance

The loan contains errors within one or more TRID disclosure. The Seller Paid fees on the Closing Disclosure in file dated XXXX do not match the Seller Paid fees on the Seller's Closing Disclosure in file dated XXXX.  Need Post Consummation Closing Disclosure (CD) with letter to borrower and proof of method of delivery reflecting all Seller paid fees in Seller-Paid column of Borrower's CD.

7000-3290

10/3/2019

Waived/Exception Granted

Compensating Factors: 1. 728 FICO scores, 48 points greater than program guideline minimum FICO scores of 680 2. Excellent mortgage payment history since inception 08/2016 3. No public records 4. 4 months reserves, 1 month greater than program guideline 3 months reserves requirement

Waived

Compliance

EG2

10/2/2019

Primary Residence

FL

x/xx/xxxx

Purchase

Non-Qualified Mortgage

EG3

EG2

EG3

EG2

EG2

EG2

EG1

EG1

EX-99.1

Exhibit 99.1 - Schedule 2

TPR Firm:	EdgeMAC	Date Submitted:	10/30/2019
Client Name:	Sprout	Report:	Rating Agency Grades
Client Project:	HOF 2019-3	Loans in report:	131

INITIAL CREDIT GRADES

INITIAL COMPLIANCE GRADES

INITIAL PROPERTY GRADES

INITIAL OVERALL LOAN GRADES

FINAL CREDIT GRADES

FINAL COMPLIANCE GRADES

FINAL PROPERTY GRADES

FINAL OVERALL LOAN GRADES

Report Date

Loan Number

Edge MAC ID

Seller Loan Number

Originator

Loan Amount

DBRS

Fitch

Kroll

Moody's

S&P

DBRS

Fitch

Kroll

Moody's

S&P

DBRS

Fitch

Kroll

Moody's

S&P

DBRS

Fitch

Kroll

Moody's

S&P

DBRS

Fitch

Kroll

Moody's

S&P

DBRS

Fitch

Kroll

Moody's

S&P

DBRS

Fitch

Kroll

Moody's

S&P

DBRS

Fitch

Kroll

Moody's

S&P

10/30/2019

430537539

XXXX

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10/30/2019

430537540

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10/30/2019

430537541

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10/30/2019

430537543

XXXX

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10/30/2019

430537544

XXXX

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10/30/2019

430537545

XXXX

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10/30/2019

430537546

XXXX

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10/30/2019

430537548

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10/30/2019

430592931

XXXX

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A

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10/30/2019

430518311

XXXX

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10/30/2019

430537549

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10/30/2019

430537550

XXXX

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10/30/2019

430537551

XXXX

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10/30/2019

430537552

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10/30/2019

430537553

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10/30/2019

430537554

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10/30/2019

430518320

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10/30/2019

430537555

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10/30/2019

430537557

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10/30/2019

430518334

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10/30/2019

430537558

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10/30/2019

430537559

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10/30/2019

430537560

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10/30/2019

430537561

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10/30/2019

430518338

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10/30/2019

430537562

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10/30/2019

430537563

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10/30/2019

430537565

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RC

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592961

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592962

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592965

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

A

A

A

A

RA

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430537663

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430537664

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

C

C

C

C

RC

C

C

C

C

VC

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430537667

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

A

A

A

A

RA

C

C

C

C

VC

C

C

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C

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A

A

A

A

CA

A

A

A

A

RA

A

A

A

A

VA

A

A

A

A

A

10/30/2019

430592970

XXXX

XXXX

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A

A

A

A

CA

B

B

B

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A

A

A

A

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B

B

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A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430537669

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

B

B

B

B

RB

A

A

A

A

VA

B

B

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A

A

A

A

CA

B

BW

B

B

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A

A

A

A

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B

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B

B

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10/30/2019

430592975

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

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C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

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B

B

B

10/30/2019

430592976

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

B

B

B

B

RB

A

A

A

A

VA

B

B

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B

B

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592977

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592978

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430537676

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

A

A

A

A

RA

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

A

A

A

A

RA

A

A

A

A

VA

A

A

A

A

A

10/30/2019

430537678

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430537680

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

B

B

B

B

RB

A

A

A

A

VA

B

B

B

B

B

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430537683

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592986

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

B

B

B

B

RB

A

A

A

A

VA

B

B

B

B

B

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592987

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

C

C

C

C

VC

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430537685

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

A

A

A

A

RA

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592993

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592994

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592998

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

A

A

A

A

RA

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

A

A

A

A

RA

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430592999

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

A

A

A

A

RA

A

A

A

A

VA

A

A

A

A

A

10/30/2019

430593008

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

B

B

B

B

RB

A

A

A

A

VA

B

B

B

B

B

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593010

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

B

B

B

RB

A

A

A

A

VA

B

B

B

B

B

10/30/2019

430593011

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593013

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593015

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

A

A

A

A

RA

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

A

A

A

A

RA

A

A

A

A

VA

A

A

A

A

A

10/30/2019

430593016

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593017

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

C

C

C

C

VC

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593019

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593020

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593021

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593023

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593025

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

C

C

C

C

VC

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593027

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593029

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593032

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593033

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593036

XXXX

XXXX

XXXX

XXXX

A

A

A

A

CA

A

A

A

A

RA

A

A

A

A

VA

A

A

A

A

A

A

A

A

A

CA

A

A

A

A

RA

A

A

A

A

VA

A

A

A

A

A

10/30/2019

430593037

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

B

B

B

RB

A

A

A

A

VA

B

B

B

B

B

10/30/2019

430593038

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593041

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593042

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593044

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

C

C

C

C

RC

A

A

A

A

VA

C

C

C

C

C

A

A

A

A

CA

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

10/30/2019

430593045

XXXX

XXXX

XXXX

XXXX

C

C

C

C

CC

B

B

B

B

RB

A

A

A

A

VA

C

C

C

C

C

B

BW

B

B

CB

B

BW

B

B

RB

A

A

A

A

VA

B

BW

B

B

B

EX-99.1

Exhibit 99.1 - Schedule 3

TPR Firm:	EdgeMAC	Date Submitted:	10/30/2019
Client Name:	Sprout	Report:	Final Tape Compare Report
Client Project:	HOF 2019-3	Loans in report:	131

Report Date	Loan Number	Edge MAC ID	Seller Loan Number	Field	Final Tape Data	Reviewer Data
10/30/2019	430537539	XXXX	XXXX	Investor Qualifying DTI	44.32	44.474
10/30/2019	430537540	XXXX	XXXX	Investor Qualifying DTI	25.76	27.610
10/30/2019	430537541	XXXX	XXXX	Investor Qualifying DTI	20.491	14.836
10/30/2019	430537541	XXXX	XXXX	Property Type	Detached	PUD (Planned Unit Development)
10/30/2019	430537544	XXXX	XXXX	Investor Qualifying DTI	30.53	30.741
10/30/2019	430537544	XXXX	XXXX	Property Type	Detached	2-4 Family
10/30/2019	430537545	XXXX	XXXX	Investor Qualifying DTI	32.928	32.998
10/30/2019	430537546	XXXX	XXXX	Amortization Term	360	276
10/30/2019	430537546	XXXX	XXXX	Investor Qualifying DTI	47.884	46.438
10/30/2019	430537548	XXXX	XXXX	Investor Qualifying DTI	42.372	42.602
10/30/2019	430592931	XXXX	XXXX	Investor Qualifying DTI	29.801	29.813
10/30/2019	430518311	XXXX	XXXX	Investor Qualifying DTI	53.589	57.748
10/30/2019	430537549	XXXX	XXXX	Investor Qualifying DTI	40.175	40.000
10/30/2019	430537550	XXXX	XXXX	Investor Qualifying DTI	40.447	40.427
10/30/2019	430537552	XXXX	XXXX	Amortization Term	480	360
10/30/2019	430537552	XXXX	XXXX	Investor Qualifying DTI	45.061	42.741
10/30/2019	430537553	XXXX	XXXX	Investor Qualifying DTI	42.099	58.53
10/30/2019	430537554	XXXX	XXXX	Investor Qualifying DTI	55.369	55.459
10/30/2019	430537554	XXXX	XXXX	Property Type	Detached	2-4 Family
10/30/2019	430537555	XXXX	XXXX	Investor Qualifying DTI	6.546	6.278
10/30/2019	430537558	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430537559	XXXX	XXXX	Investor Qualifying DTI	39.328	38.123
10/30/2019	430537560	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430537560	XXXX	XXXX	Investor Qualifying DTI	37.648	33.521
10/30/2019	430537561	XXXX	XXXX	Investor Qualifying DTI	47.35	48.232
10/30/2019	430518338	XXXX	XXXX	Investor Qualifying DTI	48.216	48.243
10/30/2019	430537562	XXXX	XXXX	Investor Qualifying DTI	25.163	23.359
10/30/2019	430537563	XXXX	XXXX	Investor Qualifying DTI	25.765	25.564
10/30/2019	430537565	XXXX	XXXX	Investor Qualifying DTI	18.824	13.820
10/30/2019	430537567	XXXX	XXXX	Investor Qualifying DTI	47.981	49.599
10/30/2019	430537571	XXXX	XXXX	Investor Qualifying DTI	42.072	40.550
10/30/2019	430592932	XXXX	XXXX	Investor Qualifying DTI	5.23	5.201
10/30/2019	430537572	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430537575	XXXX	XXXX	Qualifying Credit Score	700	697
10/30/2019	430537576	XXXX	XXXX	Investor Qualifying DTI	35.754	34.886
10/30/2019	430537577	XXXX	XXXX	Investor Qualifying DTI	13.809	13.917
10/30/2019	430537577	XXXX	XXXX	Property Type	Attached	Low Rise Condo (1-4 stories)
10/30/2019	430518351	XXXX	XXXX	Investor Qualifying DTI	33.331	33.372
10/30/2019	430592934	XXXX	XXXX	Investor Qualifying DTI	40.833	40.955
10/30/2019	430592936	XXXX	XXXX	Investor Qualifying DTI	34.371	35.428
10/30/2019	430537581	XXXX	XXXX	Investor Qualifying DTI	26.067	31.941
10/30/2019	430537582	XXXX	XXXX	Investor Qualifying DTI	45.457	44.297
10/30/2019	430537583	XXXX	XXXX	Investor Qualifying DTI	32.37	32.597
10/30/2019	430537585	XXXX	XXXX	Investor Qualifying DTI	25.114	28.987
10/30/2019	430537587	XXXX	XXXX	Investor Qualifying DTI	51.987	53.446
10/30/2019	430537587	XXXX	XXXX	Qualifying Credit Score	803	801
10/30/2019	430537592	XXXX	XXXX	Investor Qualifying DTI	14.49	17.364
10/30/2019	430537593	XXXX	XXXX	Investor Qualifying DTI	37.19	39.483
10/30/2019	430537596	XXXX	XXXX	Investor Qualifying DTI	47.456	46.458
10/30/2019	430537602	XXXX	XXXX	Investor Qualifying DTI	36.324	36.356
10/30/2019	430537607	XXXX	XXXX	Investor Qualifying DTI	37.475	36.944
10/30/2019	430537608	XXXX	XXXX	Investor Qualifying DTI	10.598	10.618
10/30/2019	430537610	XXXX	XXXX	Investor Qualifying DTI	8.385	8.745
10/30/2019	430592943	XXXX	XXXX	Investor Qualifying DTI	33.513	34.680
10/30/2019	430537612	XXXX	XXXX	Investor Qualifying DTI	41.491	41.111
10/30/2019	430537614	XXXX	XXXX	Investor Qualifying DTI	37.121	32.802
10/30/2019	430537616	XXXX	XXXX	Investor Qualifying DTI	16.955	16.648
10/30/2019	430537617	XXXX	XXXX	Investor Qualifying DTI	48.632	48.112
10/30/2019	430537618	XXXX	XXXX	Investor Qualifying DTI	33.757	33.219
10/30/2019	430537621	XXXX	XXXX	Investor Qualifying DTI	4.28	4.310
10/30/2019	430537626	XXXX	XXXX	Borrower Self-Employed	Y	No
10/30/2019	430537626	XXXX	XXXX	Investor Qualifying DTI	31.406	32.346
10/30/2019	430592946	XXXX	XXXX	Investor Qualifying DTI	38.616	35.415
10/30/2019	430592947	XXXX	XXXX	Investor Qualifying DTI	28.547	28.573
10/30/2019	430592949	XXXX	XXXX	Investor Qualifying DTI	28.626	27.981
10/30/2019	430592950	XXXX	XXXX	Investor Qualifying DTI	46.379	51.937
10/30/2019	430537629	XXXX	XXXX	Investor Qualifying DTI	24.277	23.751
10/30/2019	430537630	XXXX	XXXX	Investor Qualifying DTI	18.035	14.938
10/30/2019	430537631	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430537631	XXXX	XXXX	Investor Qualifying DTI	39.896	35.115
10/30/2019	430537633	XXXX	XXXX	Investor Qualifying DTI	48.838	48.828
10/30/2019	430592953	XXXX	XXXX	Property Type	Detached	2-4 Family
10/30/2019	430537641	XXXX	XXXX	Investor Qualifying DTI	33.269	37.099
10/30/2019	430537641	XXXX	XXXX	Property Zip	XXXX	XXXX
10/30/2019	430537642	XXXX	XXXX	Investor Qualifying DTI	36.052	46.304
10/30/2019	430537642	XXXX	XXXX	Margin	3.25	0.0000
10/30/2019	430537644	XXXX	XXXX	Investor Qualifying DTI	42.256	42.249
10/30/2019	430537647	XXXX	XXXX	Investor Qualifying DTI	41.15	40.971
10/30/2019	430592957	XXXX	XXXX	Investor Qualifying DTI	48.953	48.162
10/30/2019	430537652	XXXX	XXXX	Investor Qualifying DTI	4.431	2.055
10/30/2019	430537654	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430537654	XXXX	XXXX	Investor Qualifying DTI	25.191	27.782
10/30/2019	430537655	XXXX	XXXX	Investor Qualifying DTI	24.073	24.903
10/30/2019	430592961	XXXX	XXXX	Co Borrower 1 Self-Employed		No
10/30/2019	430592962	XXXX	XXXX	Investor Qualifying DTI	42.642	42.977
10/30/2019	430592965	XXXX	XXXX	Investor Qualifying DTI	16.407	16.409
10/30/2019	430537663	XXXX	XXXX	Investor Qualifying DTI	45.589	45.491
10/30/2019	430537663	XXXX	XXXX	Original CLTV	84.997	85.00
10/30/2019	430537663	XXXX	XXXX	Original LTV	84.997	85.00
10/30/2019	430537664	XXXX	XXXX	Investor Qualifying DTI	11.976	11.877
10/30/2019	430537667	XXXX	XXXX	Investor Qualifying DTI	33.153	17.054
10/30/2019	430592970	XXXX	XXXX	Investor Qualifying DTI	34.803	16.030
10/30/2019	430537669	XXXX	XXXX	Amortization Term	480	360
10/30/2019	430537669	XXXX	XXXX	Investor Qualifying DTI	33.994	31.811
10/30/2019	430592976	XXXX	XXXX	Investor Qualifying DTI	15.177	14.875
10/30/2019	430592977	XXXX	XXXX	Investor Qualifying DTI	46.922	42.492
10/30/2019	430592978	XXXX	XXXX	Investor Qualifying DTI	44.283	43.857
10/30/2019	430537676	XXXX	XXXX	Investor Qualifying DTI	32.913	35.996
10/30/2019	430537678	XXXX	XXXX	Investor Qualifying DTI	2.279	2.250
10/30/2019	430537680	XXXX	XXXX	Borrower Self-Employed	N	Yes
10/30/2019	430592986	XXXX	XXXX	Investor Qualifying DTI	26.421	25.104
10/30/2019	430592987	XXXX	XXXX	Investor Qualifying DTI	34.35	35.068
10/30/2019	430592987	XXXX	XXXX	Qualifying Credit Score	678	676
10/30/2019	430537685	XXXX	XXXX	Investor Qualifying DTI	31.696	32.248
10/30/2019	430592994	XXXX	XXXX	Investor Qualifying DTI	56.472	48.660
10/30/2019	430592999	XXXX	XXXX	Investor Qualifying DTI	15.682	14.451
10/30/2019	430593008	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430593008	XXXX	XXXX	Investor Qualifying DTI	16.288	16.539
10/30/2019	430593010	XXXX	XXXX	Investor Qualifying DTI	42.091	39.031
10/30/2019	430593011	XXXX	XXXX	Investor Qualifying DTI	44.64	45.148
10/30/2019	430593013	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430593013	XXXX	XXXX	Investor Qualifying DTI	40.261	50.491
10/30/2019	430593015	XXXX	XXXX	Investor Qualifying DTI	40.052	40.063
10/30/2019	430593016	XXXX	XXXX	Investor Qualifying DTI	55.724	55.706
10/30/2019	430593017	XXXX	XXXX	Investor Qualifying DTI	28.078	28.471
10/30/2019	430593019	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430593019	XXXX	XXXX	Investor Qualifying DTI	42.951	41.958
10/30/2019	430593020	XXXX	XXXX	Investor Qualifying DTI	41.003	41.908
10/30/2019	430593021	XXXX	XXXX	Investor Qualifying DTI	42.197	42.561
10/30/2019	430593023	XXXX	XXXX	Investor Qualifying DTI	32.941	32.975
10/30/2019	430593027	XXXX	XXXX	Investor Qualifying DTI	33.069	32.908
10/30/2019	430593029	XXXX	XXXX	Investor Qualifying DTI	41.87	46.917
10/30/2019	430593032	XXXX	XXXX	Appraisal Value	XXXX	XXXX
10/30/2019	430593032	XXXX	XXXX	Investor Qualifying DTI	42.981	51.197
10/30/2019	430593033	XXXX	XXXX	Investor Qualifying DTI	40.441	40.459
10/30/2019	430593036	XXXX	XXXX	Investor Qualifying DTI	43.317	41.840
10/30/2019	430593037	XXXX	XXXX	Investor Qualifying DTI	48.719	28.477
10/30/2019	430593038	XXXX	XXXX	Investor Qualifying DTI	45.956	45.658
10/30/2019	430593038	XXXX	XXXX	Property Type	PUD	Low Rise Condo (1-4 stories)
10/30/2019	430593038	XXXX	XXXX	Qualifying Credit Score	775	770
10/30/2019	430593041	XXXX	XXXX	Investor Qualifying DTI	49.873	49.884
10/30/2019	430593044	XXXX	XXXX	Investor Qualifying DTI	36.086	39.005
10/30/2019	430593045	XXXX	XXXX	Investor Qualifying DTI	46.625	45.393

EX-99.1

Exhibit 99.1 - Schedule 4

TPR Firm:	EdgeMAC	Date Submitted:	10/30/2019
Client Name:	Sprout	Report:	Valuation Summary Report
Client Project:	HOF 2019-3	Loans in report:	131

Report Date

Loan Number

Edge MAC ID

Seller Loan Number

Originator

Origination Date

Original Loan Amount

Sales Price

Original Appraised Property Value

Original Property Valuation Date

Property Value Used for Loan to Value1

Second Appraisal/ Valuation Value

Second Appraisal/ Valuation Variance Amount

Second Appraisal/ Valuation Percent

Second Appraisal/ Valuation Date

Second Appraisal/ Valuation Type

Second Full Appraisal Property Value

Second Full Appraisal Date

Original Automated Valuation Model AVM Model Name

Original AVM Confidence Score

Desk Review Property Value

Variance Percent

Desk Review Risk Score

Desk Review Date

Form 2055 Appraisal Property Value

Form 2055 Appraisal Appraisal Date

Original Automated Valuation Model AVM Property Value

Original Automated Valuation Model AVM Appraisal Date

Broker s Price Opinion BPO Property Value

Broker s Price Opinion BPO Appraisal Date

Most Recent Property Value

Most Recent Property Valuation Type

Most Recent Property Valuation Date

Most Recent AVM Model Name

Most Recent AVM Confidence Score

Collateral Underwriter Risk Score

10/30/2019

430537539

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537540

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

XXXX

XXXX

0.00 %

XXXX

XXXX

3

XXXX

10/30/2019

430537541

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

XXXX

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537543

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2.9

10/30/2019

430537544

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537545

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2.4

10/30/2019

430537546

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537548

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

-4%

XXXX

CDA

XXXX

-4.37 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592931

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

2

10/30/2019

430518311

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

-1%

XXXX

CDA

XXXX

-0.53 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537549

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

3.4

10/30/2019

430537550

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537551

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430537552

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537553

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537554

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430518320

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

-1%

XXXX

CDA

XXXX

-0.82 %

Low

XXXX

XXXX

9

XXXX

2.2

10/30/2019

430537555

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

3

XXXX

10/30/2019

430537557

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430518334

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537558

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430537559

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537560

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

5

10/30/2019

430537561

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430518338

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

-13%

XXXX

CDA

XXXX

-12.50 %

Moderate

XXXX

XXXX

9

XXXX

5

10/30/2019

430537562

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537563

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537565

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537566

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2

10/30/2019

430537567

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537570

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

Moderate

XXXX

XXXX

3

XXXX

3.4

10/30/2019

430537571

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low Risk

XXXX

XXXX

9

XXXX

10/30/2019

430592932

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537572

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537575

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537576

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537577

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430518351

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

XXXX

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592934

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2.3

10/30/2019

430592936

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

5

10/30/2019

430537581

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537582

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537583

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537584

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537585

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537587

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537588

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537589

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2

10/30/2019

430537591

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537592

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537593

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537596

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537602

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2.8

10/30/2019

430537607

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430537608

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537610

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592943

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537612

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low Risk

XXXX

XXXX

9

XXXX

10/30/2019

430537614

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537616

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537617

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

2.3

10/30/2019

430537618

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2

10/30/2019

430537621

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537626

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

1.7

10/30/2019

430592946

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592947

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

3.4

10/30/2019

430592949

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430592950

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low Risk

XXXX

XXXX

9

XXXX

2

10/30/2019

430537629

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430592951

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

XXXX

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537630

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

2

10/30/2019

430537631

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537633

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592952

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592953

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430537641

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537642

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537644

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537646

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537647

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592957

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

2.9

10/30/2019

430537652

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430537653

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537654

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

-3%

XXXX

CDA

XXXX

-3.37 %

Moderate

XXXX

XXXX

3

XXXX

10/30/2019

430537655

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low Risk

XXXX

XXXX

9

XXXX

10/30/2019

430592961

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592962

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

2

10/30/2019

430592965

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430537663

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537664

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

3

XXXX

10/30/2019

430537667

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430592970

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

moderate

XXXX

XXXX

9

XXXX

2.3

10/30/2019

430537669

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430592975

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

Low

XXXX

XXXX

3

XXXX

2.3

10/30/2019

430592976

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

9/5/2019

XXXX

XXXX

9

XXXX

10/30/2019

430592977

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430592978

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2.7

10/30/2019

430537676

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430537678

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537680

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430537683

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430592986

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430592987

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low Risk

XXXX

XXXX

9

XXXX

10/30/2019

430537685

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

XXXX

XXXX

9

XXXX

10/30/2019

430592993

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430592994

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

Moderate Risk

XXXX

XXXX

3

XXXX

2

10/30/2019

430592998

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

1.8

10/30/2019

430592999

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low Risk

XXXX

XXXX

9

XXXX

10/30/2019

430593008

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593010

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low Risk

XXXX

XXXX

9

XXXX

10/30/2019

430593011

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430593013

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593015

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430593016

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

5%

XXXX

CDA

XXXX

5.26 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593017

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593019

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

3.1

10/30/2019

430593020

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593021

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430593023

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593025

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

2.9

10/30/2019

430593027

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593029

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

10/30/2019

430593032

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593033

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

3.1

10/30/2019

430593036

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

2.2

10/30/2019

430593037

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

XXXX

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430593038

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate Risk

XXXX

XXXX

9

XXXX

2

10/30/2019

430593041

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

10/30/2019

430593042

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Moderate

XXXX

XXXX

9

XXXX

2.1

10/30/2019

430593044

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

10/30/2019

430593045

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

$0.00

0%

XXXX

CDA

XXXX

0.00 %

Low

XXXX

XXXX

9

XXXX

EX-99.2

Exhibit 99.2

October 31, 2019
Due Diligence Narrative Report

Table of Contents

Clayton Contact Information	2
Overview	2
Originators	2
Clayton’s Third Party Review (“TPR”) Scope of Work	3
Sampling	3
Sponsor Acquisition Criteria	3
Loan Grading	3
TPR Component Review Scope	4
Credit Review	4
Property Valuation Review	4
Regulatory Compliance Review	5
Data Integrity	6
Data Capture	6
Data Compare Results	6
Clayton Due Diligence Results	7
Clayton Third Party Reports Delivered	10
Appendix A: Credit Review Scope	11
Appendix B: Origination Appraisal Assessment	14
Appendix C: Regulatory Compliance Review Scope	16

HOF 2019-3 Due Diligence Narrative Report Page | 1 October 31, 2019

Clayton Contact Information

Client Service Management:

Adam Peat	Client Service Manager
	Phone: (813) 472-6417/E-mail:  apeat@radian.com

Joe Ozment	Director of Securitization
	Phone: (813) 261-0733/E-mail: jozment@clayton.com

Overview

On behalf of 5^th Street Mortgage Clayton conducted an independent third-party pre-securitization due diligence review of 6 residential loans.

On behalf of JP Morgan Clayton conducted an independent third-party pre-securitization due diligence review of 1 residential loan.

On behalf of Impac Mortgage Clayton conducted an independent third-party pre-securitization due diligence review of 1 residential loans.

Neuberger Berman subsequently purchased these loans via reliance letter and selected them for the HOF 2019-3 transaction.

The loans referenced in this narrative report were reviewed on a flow basis from May 2018 to September 2019 at Clayton’s centralized underwriting facilities in Tampa, FL. This narrative report provides information about the original lenders, the scope of work performed by Clayton, and the results of Clayton’s review.

Originators

Origination channels for the loans in this review:

Origination Channel	Loan Count	Percentage
Broker	8	100.00%
Total	8	100.00%

HOF 2019-3 Due Diligence Narrative Report Page | 2 October 31, 2019

Clayton’s Third Party Review (“TPR”) Scope of Work

The scope of work for this transaction consisted of credit, property valuation, and regulatory compliance reviews, plus a data integrity check, and was performed in accordance with rating agency1 loan level review standards in place as of the date of the review. This is referred to as a “Full Review.”

Sampling

For all originators in this transaction, 100% of the loans received a Full Review as described below.

Review Type Loan Counts:

Review Type	Loan Count Reviewed by Clayton	Scope Applied
Full Review	8	Clayton performed a Full Review based on the scope described below in the section titled “TPR Component Review Scope”.
Total Loan Population	8

Sponsor Acquisition Criteria

The loans were originated to each Seller’s Guidelines and Clayton reviewed the loans to each Seller Guide Loan Eligibility Requirements, (“Sponsor Acquisition Criteria”). Clayton was supplied with all of the changes to the guidelines with advance notice. Guidelines presented were:

Primary Guideline

IMPAC/IQM Alt Doc Program/07/2016

5th Street Capital/Bank Statements/10/2019

5th Street Capital/Full Doc/10/2019

Stearns/Jumbo Guidelines 8.28.18/8/2018

Loan Grading

The Sponsor Acquisition Criteria referenced above served as the benchmark for grading loans from a credit underwriting, property valuation and regulatory compliance perspective, as applicable. Each loan received an “initial” and a “final” grade. The “initial”

HOF 2019-3 Due Diligence Narrative Report Page | 3 October 31, 2019

grade was assigned during the initial loan review. The “final” grade takes into account additional information and supporting documentation that may have been provided by the originators to clear outstanding conditions. Clayton’s loan grading is solely based on Clayton’s independent assessment of all guideline exceptions and compensating factors for each of the component reviews. Clayton is providing a comprehensive loan-level analysis as part of this pre-securitization reporting package that includes initial grades, final grades and detailed commentary on the rationale for any changes in grades, and sets forth compensating factors and waivers.

Clayton’s loan grading complied with rating agency grading definitions published by Moody’s, Standard and Poor’s, Fitch, Kroll, DBRS and Morningstar.

TPR Component Review Scope

Clayton examined the selected loan files with respect to the presence or absence of relevant documents, enforceability of mortgage loan documents, and accuracy and completeness of data fields. Clayton relied on the accuracy of information contained in loan documentation provided to Clayton.

Credit Review

Clayton’s Credit scope of review conducted on this transaction included the following elements (for more detail, please refer to Appendix A and to the guidelines cited above):

§ Assessed whether the characteristics of the mortgage loans and the borrowers conformed to the Sponsor Acquisition Criteria cited above;

§ Re-calculated LTV, CLTV, income, liabilities, and debt-to-income ratios (DTI) and compared these against the Sponsor Acquisition Criteria;

§ Analyzed asset statements in order to determine whether funds to close and reserves were within Sponsor Acquisition Criteria;

§ Confirmed that credit scores (FICO) and credit histories were within Sponsor Acquisition Criteria;

§ Evaluated evidence of borrower’s willingness and ability to repay the obligation;

§ Examined Data Verify risk evaluation report, which was located in each loan file, for income, employment, Nationwide Mortgage Licensing System and Registry (“NMLS”) and occupancy status alerts. Clayton researched alert information against loan documentation and assigned loan conditions accordingly

Property Valuation Review

Clayton’s Property Valuation scope of review conducted on this transaction included the following elements:

§ Original Appraisal Assessment

- Clayton reviewed the original appraisal provided to determine whether the original appraisal was complete, thorough and the original appraised value was reasonably supported.

- For more detail on the original appraisal review scope and desk review definitions, please refer to Appendix B and to the guidelines cited above.

§ Value Supported Analysis

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

HOF 2019-3 Due Diligence Narrative Report Page | 4 October 31, 2019

- 8 of 8 loans had a Desktop review ordered by Clayton supporting value within -10%

Regulatory Compliance Review

Clayton’s Regulatory Compliance scope of review conducted on this transaction included the elements summarized below. (For more detail, please refer to Appendix C and to the guidelines cited above.)

Clayton utilized its proprietary eCLAS engine for regulatory compliance testing.

The scope of the compliance review performed is summarized below:

§ Tested for certain applicable federal, state and local high cost and/or anti-predatory laws;

§ Assessed compliance with state specific consumer protection laws by testing late charge and prepayment penalty provisions;

§ Truth-in-lending/regulation Z (TILA) testing included the following:

- Notice of Right to Cancel (Right of Rescission) adherence if applicable;

- TIL Disclosure Timing (3/7/3) and disclosure content;

- TIL APR and Finance charge tolerances;

- Timeliness of ARM Disclosures (if applicable);

- Section 32 APR and Points and Fees Thresholds and prohibited practices;

- Section 35 Higher Priced Mortgage Loans thresholds and applicable escrow and appraisal requirements;

- Prohibited Acts or Practices including Loan Originator compensation rules, NMLSR ID on documents, financing Credit Insurance, mandatory arbitration clauses, and NegAm Counseling;

- Reviewed ATR/QM Ability to Repay (a/k/a Minimum Standards for Transactions): for applications on or after 1/10/2014. Clayton confirmed the loan files contain documentation to evidence the lender considered and verified the borrower’s ability to Repay. This included identifying whether QM loans met agency exemptions or were underwritten in accordance with Appendix Q.  Non-QM loans were reviewed to ensure the lender documented that they considered and verified the eight (8) underwriting factors required for ATR compliance in accordance with either their guidelines or the Sponsor Acquisition Criteria;

oThe ATR/QM Rules allow the lender to exclude up to two discount points from the 3% points and fees evaluation depending on the loan’s undiscounted interest rate in relation to the APOR index rate. The ATR/QM Rule does not set the required rate reduction per discount point.

Clayton evaluated the lender’s exclusion of discount points from the 3% points and fees calculation for all loans in this transaction using a [0.2%] rate reduction threshold per discount point.

- Prepayment Penalty restrictions.

- TRID: on applicable loans, test compliance with the Integrated Mortgage Disclosure rules under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) defined under the Dodd-Frank Wall Street Reform and Consumer Protection Act as promulgated by the Consumer Financial Protection Bureau.

§ Real Estate Settlement Procedures Act (RESPA) laws and regulations testing included:

- GFE initial disclosure timing and content;

- Confirmed the file contains the final HUD1 Settlement Statement; 

- GFE to HUD1 evaluation for 0% and 10% fee tolerances;

- Homeownership Counseling Notice;

- Affiliated Business Disclosure if applicable.

OF NOTE: As of October 3, 2015 (“TRID Effective Date”), Clayton commenced testing applicable loans subject to the TRID Effective date against a TRID scope of review that was based on outside counsel’s interpretations of the published regulations as of the TRID Effective Date. Clayton’s scope was commercially reasonable as it relates to a Third Party Review (“TPR”) firm’s role as TPR conducting an independent third-party pre-securitization due diligence review (“Initial TRID Scope”). The Initial TRID Scope was created with guidance from outside counsel.

HOF 2019-3 Due Diligence Narrative Report Page | 5 October 31, 2019

On, June 15th, 2016 SFIG published its RMBS 3.0 TRID Compliance Review Scope © documentation, developed under the leadership of members from Third Party Review (“TPR”) firms across the industry and SFIG’s RMBS 3.0 Due Diligence, Data and Disclosure Working Group. The RMBS 3.0 TRID Compliance Review Scope was created with an aim to facilitate a uniform testing and risk identification standard as it would apply to an assignee, as a result of a consistent Truth-In-Lending Act liability interpretation according to the understanding of prevailing legal precedent and informal written guidance and webinars offered by the CFPB, as it applies to the Know Before You Owe / Truth In Lending Act (“TILA) – Real Estate Settlement Procedures Act (“RESPA”) Integrated Disclosure (“TRID”) Rule (78 FR 79730, as amended). RMBS 3.0 TRID Compliance Review Scope may be formally amended by the SFIG RMBS 3.0 Due Diligence, Data and Disclosure Working Group as clarifying regulations may be promulgated on a go forward basis, as well as any binding judicial interpretations of the underlying law.

Following the June 15^th formal publication of the RMBS 3.0 TRID Compliance Review Scope ©, Clayton reviewed prior testing results dating back to the TRID Effective Date, and applied the enhanced RMBS 3.0 TRID Compliance Review Scope to such loans upon the affirmative election of the both Impac and Sprout.

Clayton applied the enhanced RMBS 3.0 TRID Compliance Review Scope to all loans in this transaction.

Data Integrity

Clayton utilized its proprietary eCLAS tool to determine tape to file accuracy of each reviewed loan, by completing the following steps:

§ Tape data received from lender/client is stored in eCLAS;

§ Loan Reviewer collects validated loan data in eCLAS;

§ Each received data point is compared to its counterpart collected data point;

§ Discrepancies found during comparison are stored

Data Capture

Clayton collected data fields required to create the American Securitization Forum (“ASF”) Upload. The file format was provided as part of the pre-securitization reporting package. Additionally, Clayton captured rating agency required data points relating to ATR/QM determination, which is provided in the reporting package.

Data Compare Results

Clayton provided Neuberger Berman with a copy of the Loan Level Tape Compare Upload which shows the differences between the data received by the sellers versus the data captured by Clayton during the loan review.

Summary of data compare results:

Field Name	Count	Accuracy %
Combined Loan to Value	1	87.50%
DTI (Back)	2	75.00%

HOF 2019-3 Due Diligence Narrative Report Page | 6 October 31, 2019

Lender ATR/QM Status	1	87.50%
Loan Doc Type	2	75.00%
Loan to Value	1	87.50%
Qualifying DTI (Back)	1	87.50%
Representative Score	1	87.50%

Clayton Due Diligence Results

Below are the initial and final overall loan grades for this review, as well as the credit, property valuation, and regulatory compliance component review grades.

Initial and Final Overall Loan Grade Results (DBRS)

	Overall Grade Migration
	Initial
Final		A	B	C	D	Total
	A				1	1
	B		2	4	1	7
	C					0
	D					0
	Total	0	2	4	2	8

*The overall grade summary reflects the combination of the credit, property valuation and regulatory compliance component reviews into one overall grade. The overall grade assigned is the most severe grade from each of the component reviews.

HOF 2019-3 Due Diligence Narrative Report Page | 7 October 31, 2019

Initial and Final Credit Component Grade Results (DBRS)

	Credit Grade Migration
	Initial
Final		A	B	C	D	Total
	A	2	1			3
	B		3	1	1	5
	C					0
	D					0
	Total	2	4	1	1	8

Initial and Final Property Valuation Grade Results (DBRS)

	Property Valuation Grade Migration
	Initial
Final		A	B	C	D	Total
	A	7		1		8
	B					0
	C					0
	D					0
	Total	7	0	1	0	8

Initial and Final Regulatory Compliance Grade Results (DBRS)

	Compliance Grade Migration
	Initial
Final		A	B	C	D	Total
	A	1			2	3
	B		1	4		5
	C					0
	D					0
	Total	1	1	4	2	8

HOF 2019-3 Due Diligence Narrative Report Page | 8 October 31, 2019

Initial and Final Overall Loan Grade Results (S&P)

	Overall Grade Migration
	Initial
Final		A	B	C	D	Total
	A				1	1
	B		2	4	1	7
	C					0
	D					0
	Total	0	2	4	2	8

*The overall grade summary reflects the combination of the credit, property valuation and regulatory compliance component reviews into one overall grade. The overall grade assigned is the most severe grade from each of the component reviews.

Initial and Final Credit Component Grade Results (S&P)

	Credit Grade Migration
	Initial
Final		A	B	C	D	Total
	A	2	1			3
	B		3	1	1	5
	C					0
	D					0
	Total	2	4	1	1	8

Initial and Final Property Valuation Grade Results (S&P)

	Property Valuation Grade Migration
	Initial
Final		A	B	C	D	Total
	A	7		1		8
	B					0
	C					0
	D					0
	Total	7	0	1	0	8

HOF 2019-3 Due Diligence Narrative Report Page | 9 October 31, 2019

Initial and Final Regulatory Compliance Grade Results (S&P)

	Compliance Grade Migration
	Initial
Final		A	B	C	D	Total
	A	1			2	3
	B		1	4		5
	C					0
	D					0
	Total	1	1	4	2	8

Clayton Third Party Reports Delivered

Clayton furnished the following reports on this transaction:

1. Narrative Report

2. Conditions Report

3. Loan Level Tape Compare Upload

4. Waived Conditions Summary Reports

5. Valuations Summary Reports

6. Business Purpose Supplement

7. NON-ATR QM Upload

8. Attestation Forms

9. ASF Upload + Addendum

10. Rating Agency ATR/QM Data Fields

HOF 2019-3 Due Diligence Narrative Report Page | 10 October 31, 2019

Appendix A: Credit Review Scope

For each mortgage loan, Clayton performed a guideline review utilizing specific guidelines furnished at the time of the review.

A. Verified that the characteristics of the mortgage loan and borrower conformed to the Sponsor Acquisition Criteria requirements including:

o DTI

o LTV/TLTV/HLTV

o Credit score

o Income and employment

o Assets and reserves

o Property type and use eligibility; and if the property type was a condominium or cooperative, assessed project adherence

o Borrower eligibility, including:

-Citizenship status

-Non- occupant co-borrower

o Transaction eligibility, including:

-Maximum loan amount

-Loan purpose

-Occupancy

o Noted any approved exceptions or waivers by the originator and/or aggregator to guidelines; verified that approved exceptions included required, documented compensating factors

B. As part of the guideline review, Clayton performed a credit analysis during which various documents were examined, including:

o Uniform Residential Loan Application reviewed to determine:

- Initial loan application was in the loan file and was signed by all borrowers

- Final loan application was in the loan file and was complete

- Information and debts disclosed on loan application aligned with related documentation in the loan file

o Employment analyzed and verified through use of various documents, including:

- Income documentation

- Verbal and/or written verifications of employments (VVOE, VOE)

- CPA letter

- Business licenses

- Tax transcripts (IRS Form 4506-T)

- Other documentation in loan file

o Income review included:

- Required income documentation for all borrowers was present and within required time period

- Documents did not appear to have been altered or inconsistent

- IRS Form 4506-T

§ Signed by all borrowers and processed by the originator

§ Compared IRS tax transcripts to income documentation and noted any inconsistencies

- Income was recalculated and was documented with applicable documentation, including:

§ Tax returns

§ Financial statements

§ Paystubs

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§ W-2s

§ 1099

§ IRS documents

§ Bank statements

§ Lease agreements

§ Award letters

§ Other documentation in loan file

o Asset review included:

- Asset documentation required to verify down payment, closing costs, prepaid items and reserves was present and within required timeframe, including:

§ Verification of deposits (VOD)

§ Depository account statements

§ Stock or security account statements

§ Gift funds

§ Settlements statements

§ Other evidence of conveyance and transfer of funds, if a sale of assets was involved

§ Other documentation in loan file

- Asset documents were reviewed to determine any large deposits and appropriate sourcing of funds

o Credit Report review included:

- Complete copy of report was in loan file

- Report was dated within required timeframe

- All borrowers were included in the report

- Checked any fraud alerts against related loan file documentation

- Verified all disclosed mortgage debt on credit report against the loan application (under the schedule of real estate owned) for accurate debt ratio calculation

- Compared liabilities listed on the credit report against the loan application for accurate debt ratio calculation

- Captured and utilized appropriate credit score for guideline review

o Title policy review included:

- Title interest – determined if

§ Fee simple

§ Leasehold estate

- Appropriate vestee(s) were listed on title policy

- Amount of coverage was greater than or equal to the original principal amount of the mortgage

- Applicable title endorsements were present

- Checked for any encumbrances, encroachments and other title exceptions affecting the lien identified through the title search; verified that each issues was addressed in the transaction

- Reviewed the chain of title and duration of ownership by seller or borrower (whichever was applicable)

- Captured monthly tax payments in debt ratio calculation

o HUD1 (Settlement Statement) review included:

- Funds to close identified and analyzed against borrower’s assets

- Seller contributions did not exceed maximum allowed

- Subject property, seller and borrower aligned with other loan documentation

- Disbursements and pay-offs included in debt ratio calculations

- Loan purpose confirmed

o Hazard/Flood insurance review included:

- Verified presence of required hazard insurance and flood insurance (if required)

- Confirmed that any required insurance was for the:

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§ Correct borrower

§ Correct property

§ Correct lender

§ Correct loan number

§ Life of loan, if flood insurance required

- Confirmed that any required insurance minimum coverage amount and policy period

- Reviewed for evidence that any required insurance policy premium was paid

- Confirmed that the mortgagee clause listed the lender’s name and “it’s successors and assigns”

- Confirmed that the payment amount on any required insurance was included in the debt ratio calculation

o Mortgage Insurance review included:

- Determined if mortgage insurance is required

- Captured mortgage insurance name, certificate # and percentage guarantee (when required)

C. For each mortgage loan, Clayton examined the mortgage or deed of trust for evidence of recordation. In lieu of a copy of the mortgage or deed of trust with recording information, a copy of the mortgage or deed of trust that is stamped “true and certified copy” by the escrow/settlement agent plus recording directions on closing instruction documentation was utilized as evidence for recording.

D. For each mortgage loan, Clayton utilized the results from an independent, third-party fraud tool along with information in the loan file to identify and address any potential misrepresentations including:

o Borrower identity

- Social Security inconsistencies

- Borrower name variations

o Occupancy

- Borrower address history

- Subject property ownership history

o Employment

o Licensing – reviewed NMLS data for:

- Mortgage lender/originator

- Loan officer

o OFAC

HOF 2019-3 Due Diligence Narrative Report Page | 13 October 31, 2019

Appendix B: Origination Appraisal Assessment

For each Mortgage Loan, Clayton performed the following origination appraisal analysis:

A. Verified that the mortgage loan file contained an appraisal report and that it met the following criteria:

o Appraisal report used standard GSE forms, appropriate to the property type:

- FNMA 1004/FHLMC 70 – Uniform Residential Appraisal Report. Used for 1-unit properties, units in planned unit developments (detached PUDs) and condominium projects that consist solely of detached dwelling (site condominium)

- FNMA 1073/FHLMC 465 – Individual Condominium Report. Used to appraise a unit in a condominium project or a condominium unit in a PUD (attached PUD)

- FNMA 1025/FHLMC 72 – Small Residential Income Property Appraisal Report. Used for all two-to-four unit residential income properties, including two-to-four unit properties in a PUD

- FNMA 2090 – Individual Cooperative Appraisal Report. Used for individual cooperative units

- FNMA 2000/FHLMC 1032 – One Unit Residential Appraisal Field Review

- FNMA 2000a/FHLMC 1072 – Two to Four Unit Residential Appraisal Field Review

o Appraisal report was reasonably complete and included:

- Appraisal report form, certification, statement of limiting conditions and scope of work

- Accurate identification of the subject property

- Accurate identification of the subject loan transaction

- Accurate identification of the property type, in both land and improvements

- All required attachments including:

§ Subject front, rear and street photos and valued features

§ Subject interior photos – kitchen, all baths, main living area, updates/upgrades, deferred maintenance

§ Photos of all comparable sales and listings

§ Location map

§ Exterior sketch of property with dimensions

§ 1004MC Market Conditions Report

- Evidence that appraisal report was made “As Is” or provided satisfactory evidence of completion for all material conditions

- Appraisal date met supplied Sponsor Acquisition Criteria

- If applicable to Sponsor Acquisition Criteria requirements, a second full appraisal was furnished and met Sponsor Acquisition Criteria

B. Performed a general credibility assessment of the results of the appraisal per Title XI of FIRREA and USPAP based on the following criteria:

o Title XI of FIRREA:

- If the appraisal was completed by a trainee or licensed appraiser unqualified to independently sign the report, an appropriately licensed appraiser co-signed as a supervisory appraiser and inspected the property

- Determined that either the appraiser or supervisory appraiser was appropriately licensed by verifying the appraiser’s license included in the appraisal.

- Reviewed for the presence of any “red flags” related to the mortgaged property that may have posed a risk to the property or occupants

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o USPAP

- Confirmed that the appraiser developed and communicated their analysis, opinion, and conclusion to intended users of their services in a manner that is meaningful and not misleading and that the appraisal is signed.

C. Reviewed and graded the appraisal valuation to the following criteria:

o Appraised value was reasonably supported. Utilized the following review in making value supported determination:

- Comps used were located reasonably close to the subject property and if not the reason was satisfactorily explained

- Comps used were reasonably recent in transaction date and if not the reason was furnished

- Comps used were reasonably similar to the subject property and if not an explanation was supplied

- Appraised value of the subject was bracketed by the sales prices of the comps and if not the reason was furnished

- Adjustments were reviewed and appeared reasonable utilizing the 15% net/25% gross guideline.

o Property was complete. However, if the property was not 100% complete, then any unfinished portion had no material impact to the value, safety, soundness, structural integrity, habitability or marketability of the subject property

o Appraisal was reviewed for any indication of property or marketability issues. Utilized the following key points in making determination:

- Appraisal was made on an “As Is” basis or provides satisfactory evidence of completion of all material conditions

- Property usage was reviewed for zoning compliance

- Property utilization was reviewed to determine it was “highest and best use”

- Neighborhood values were reviewed to determine if declining

- Market conditions were reviewed to determine indication of possible marketability issues:

§ Location

§ % built up

§ Growth rate

§ Demand/supply

§ Marketing time

§ Predominant occupancy

- Physical condition of the property was reviewed to determine that the property condition was average or better

- Style of property was reviewed to determine if unique property

- Any health and safety issues were noted and/or remediated

- Locational and/or environmental concerns adequately addressed if present

D. Property Eligibility Criteria – Clayton reviewed the property to determine that the property met the client supplied eligibility requirements. Examples of ineligible property types may include:

o 3 to 4 unit owner occupied properties

o 2 to 4 unit second homes

o Unwarrantable or limited review condominiums

o Manufactured or mobile homes

o Condotel units

o Unique properties

o Working farms, ranches or orchards

o Mixed-use properties

o Properties subject to existing oil or gas leases

o Properties located in Hawaii Lava Zones 1 and 2

o Properties exceeding Sponsor Acquisition Criteria requirements for excess acreage

E. Properties Affected by Disasters Criteria – Clayton reviewed the appraisal date against any FEMA Declared Disaster Areas that were designated for Individual and/or Public Assistance due to a federal government disaster declaration.

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o If the appraisal date is before the FEMA Effective Date for any of the disasters listed, Clayton will specify whether or not there has been a property inspection since the date listed, the latest inspection date, whether or not new damage has been indicated, and the amount of said damage.

F. Disclaimer

o The individuals performing the aforementioned original appraisal assessment are not persons providing valuations for purposes of the Uniform Standards of Professional Appraisal Practice (“USPAP”) or necessarily licensed as appraisers under Federal or State law, and the services being performed by such persons do not constitute “appraisal reviews” for purposes of USPAP or Federal or State law.

o Clayton makes no representation or warranty as to the value of any mortgaged property, notwithstanding that Clayton may have reviewed valuation information for reasonableness

o Clayton is not an ‘AMC’ (appraisal management company) and therefore Clayton does not opine on the actual value of the underlying property

o Clayton is not a ‘creditor’ within the meaning of ECOA or other lending laws and regulations, and therefore Clayton will not have any communication with or responsibility to any individual consumer concerning property valuation.

o Clayton does not check to see if the appraiser is on the Freddie Mac exclusionary list

G. Desk Review definitions

o Clear Capital “CDA” means a written retrospective analysis of an appraisal of residential real property relating to completeness, reasonableness, and relevance. The relevant appraisal shall be provided to Clear Capital by Customer. The CDA will offer an alternative value, if deemed appropriate, based on the analysis of the competitive market as of the effective date of the appraisal provided.  The CDA will also provide an analysis of the appraisal provided, including supporting narrative and data to fully support the CDA value and outline deficiencies within the appraisal. The CDA will also contain a Risk Score and Risk Indicators based upon the findings of the analysis for the appraisal provided to Clear Capital by Customer. 

o ProTeck’s Appraisal Risk Review (ARR) is an enhanced desk review of the original appraisal in the file completed by a licensed appraiser. The ARR validates subject and comparable data and characteristics, confirms the original appraiser’s methodologies, credentials, and commentary to insure compliance with regulatory requirements and industry accepted best practices, and flags all risk factors while also providing a final value reconciliation used to grade the loan.

HOF 2019-3 Due Diligence Narrative Report Page | 16 October 31, 2019

Appendix C: Regulatory Compliance Review Scope

This appendix provides an overview of Clayton’s proprietary compliance system for 1-4 family residential mortgage loans in the due diligence process to determine, to the extent possible and subject to the caveats below, whether the loans comply with federal, state and local laws. The Disclaimer section explains limitations that you should be aware of. Additional details on the items listed below as well as Clayton’s state, county and municipal testing can be provided upon request. The compliance engine is fully integrated into Clayton’s proprietary due diligence platform, eCLAS.

Federal Law

A. RESPA and Regulation X: Loan level analysis on the following:

o GFE/HUD1: confirm the correct version of the GFE and HUD1 were properly completed under the Regulation X Final Rule that became mandatory on January 1, 2010

o Initial Good Faith Estimate, (GFE): timing and content of the initial disclosure

o Final GFE: Verification that increases to fees from the initial GFE were disclosed within 3 days of valid changed circumstance documentation within the loan file

o Final HUD1 Settlement Statement: verify the loan file contains the final HUD1 and the loan terms on the HUD1 correspond to the actual loan terms from the Note

o Final GFE to HUD1 tolerance fee evaluation: confirm the fees charged on the HUD1 do not exceed the Final GFE in the 0% or 10% fee tolerance categories, including a review for a Settlement Service Provider List if the lender excludes fees that the borrower can shop for.

o Affiliated Business Disclosure: if the loan file indicates the lender or broker referred the borrower to a known affiliate, confirm the disclosure was provided to the borrower

o Homeownership Counseling Notice: for loan applications on or after 1/10/2014, confirm the notice was provided to the borrower within 3 days of application

B. Truth in Lending Act and Regulation Z - Loan level analysis on the following:

o TIL Disclosure: Content of Disclosures – perform an independent recalculation of the finance charges and APR to determine whether the amounts disclosed on the final TIL were within allowable tolerances. Payment schedule accuracy, including under the Mortgage Disclosure Improvement Act for loans applications on or after January 30, 2010. Additional disclosure content with a focus on the consistency of the prepayment penalty disclosure and assumption policy with the note and security instrument.

o Mortgage Disclosure Improvement Act, (3/7/3 rule): Confirm the timing of the initial TIL disclosure within 3 days of application, 7 days prior to consummation, and corrected TIL disclosures provided at least 3 days prior to consummation for applications received on or after July 30, 2009 (Section 19)

o ARM Disclosure: confirm these disclosures are in the file within 3 days of application, or 3 days of the borrower discussing ARM programs identified within the loan file

o Right of Rescission – Review the disclosure form type, disclosure timing, disclosed dates, other material disclosures, and the loan disbursement (Section 23)

o High Cost mortgage thresholds for points and fees (Section 32)

o High Cost Prohibited Acts and Practices upon request (Section 33)

o Higher Priced Mortgage Loan thresholds for APR in relation to the APOR. Including Escrow and appraisal requirements (Section 35)

o Prohibited Acts or Practices including testing the Loan Originator compensation rules, NMLSR ID on documents, financing Credit Insurance, mandatory arbitration clauses, and NegAm Counseling (Section 36)

o ATR/QM Ability to Repay, aka Minimum Standards for Transactions: for applications on or after 1/10/2014, confirm the loan file contains documentation to evidence the lender considered and verified the borrower has the ability to repay in accordance with the ATR requirements This included identifying whether QM loans met agency exemptions or were underwritten in accordance with Appendix Q. Non QM loans will be reviewed to ensure the lender documented that they considered and verified the 8 underwriting factors as required for ATR compliance. This review also includes evaluating loans against the new TILA prepayment penalty restrictions (Section 43)

o TILA/RESPA Integrated Disclosure Rule: “The Initial TRID Scope” and “RMBS 3.0 TRID Compliance Review Scope ©”

§ Test whether or not the loan is subject to disclosure on TRID documents, the Loan Estimate (“LE”) and Closing Disclosure (“CD”)

§ Pre-application Requirement Testing:

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· Pre-application forms cannot look similar to the LE

· Pre-application forms must contain the required disclaimer (“Your actual rate, payment, and costs could be higher. Get an official Loan Estimate before choosing a loan”).

§ Timing Requirements:

· The LE was delivered or placed in the mail within 3 business days of the broker or lender receiving an application.

· The loan does not consummate (Clayton looks to the later of the note date or notary date) until the later of seven business days after the LE is delivered or placed in the mail and three business days after the CD (or Corrected CD when a new three-day waiting period is triggered) is received.

· That a revised LE or CD is provided within three business days of the lender having knowledge of the information that led to the change.

§ Fee Tolerances:

· Zero and ten percent tolerance fees are only reset with a valid and timely change of circumstance.

· If a credit or refund is made, that it is sufficient to cover Clayton’s calculated under-disclosure.

§ Payment Schedule Accuracy:

· The number of columns and timing of changes to payments as well as the mortgage insurance drop-off match Clayton’s calculated payment schedule.

· Interest-only periods and final balloon payments are accurately completed.

· The total of the principal and interest payment, mortgage insurance and escrow amounts add up correctly.

· When applicable, that the AIR and AP tables are consistent with Clayton’s calculations.

§ Accuracy of the Loan Calculations

· Amount Financed

· Finance Charge

· Total of Payments

· Total interest percentage

§ Technical Requirements

· Compliance with the TRID rounding rules.

· Compliance with specified formatting requirements.

· Compliance with date entry requirements (such as when a field, if not applicable, must be present and left blank).

· Alphabetization of fees.

· Title fees preceded by “Title –.”

· Column or similar limits such as four columns for Projected Payments and a maximum of thirteen Origination Charges on the LE.

§ Consistency within and across forms

· Once a fee is disclosed it must remain substantially the same name across disclosures.

· Consistency between the Costs at Closing and Calculating Cash to Close tables, for which there is a version for transactions with a seller and an optional, but not required, version for transactions without a seller. They should be consistent within and across disclosures.

· Where amounts in a table reference that they are derived from another section of the form, that the amounts match the amount in the section referenced.

· Escrow amounts disclosed in the Projected Payments section tie out to the escrow amounts detailed in the Loan Disclosures section.

§ Completion of the LE and CD

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· All required fields not specifically listed herein are completed or left blank in accordance with TRID rules; creditor information, contact information, rate lock information, etc.

· For areas where multiple options are provided, such as Assumption, Negative Amortization and Liability after Foreclosure, only one option is indicated.

· That there is either a signature or a Loan Acceptance statement on the form.

§ Waivers

· Clayton will capture if the borrower waived their waiting period and the sufficiency of the waiver under TRID. However, based on past experience with clients, Clayton will also issue an exception for the loan closing early.

§ Corrected CD requiring a new waiting period

· Whether the APR increased or decreased outside of tolerance requiring a new waiting period and whether that waiting period was provided. For APR decreases Clayton will look to whether the APR decreased due to a reduced finance charge, which will be considered to be within tolerance.

· Whether the product or a product feature changed which requires a new waiting period and whether that waiting period was provided.

· Whether a prepayment penalty was added requiring a new waiting period and whether that waiting period was provided.

§ Post-Close CD’s

· Corrected CD’s provided with a post-close refund.

· Post-close CD’s to correct numerical errors based on events (such as recording) occurring within 30 days of consummation.

· Post-close CD’s to correct non-numerical clerical errors required within 60 days of consummation.

§ Related Documentation

· Provision and timing of Your Home Loan Toolkit (first lien, purchase-money loans)

· Written List of Providers, when there are items in in the Services You Can Shop For category (can impact fee tolerances)

· Affiliated Business Disclosure (can impact fee tolerances)

§ Outside of Clayton’s default TRID scope:

· Accuracy of the LE in terms of whether fees are within the correct category and loan terms where we would need a Note to verify. More detailed testing will occur by comparing the final CD to the Note terms.

· Whether the Liability after Foreclosure selection is correct for the property state.

· Accuracy of the Aggregate Adjustment amount.

· Presence and accuracy of the Seller’s Transaction columns of the Summaries of Transactions section.

· Accuracy of the Contact Information for the lender, broker and settlement agent. Clayton will look for discrepancies across forms, but is not independently verifying the information.

C. FACTA - the Credit Score, Key Factors, and Notice to Home Loan Applicant disclosures

D. HMDA – Whether the loans is Rate Spread threshold reportable.

STATE, COUNTY and MUNICIPAL LAW

A. Higher-Priced

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Clayton test whether a loan meets the thresholds for a higher-priced, rate spread, subprime or nonprime mortgage loan, and whether such loan meets regulatory requirements, in the following states:

Higher-Priced
California	Maryland	New York
Connecticut	Massachusetts (subprime ARMS to first time homebuyers)	North Carolina
Maine	Minnesota

B. State/Local High Cost

Clayton test whether a loan meets the thresholds for a high cost or covered loan in the following states, counties and municipalities, and also tests for compliance with provisions in such laws that apply to all loans subject to high cost testing:

State/Local High Cost
Arkansas	Maine	Pennsylvania
California	Maryland	Rhode Island, including the Providence ordinance
Colorado	Massachusetts	South Carolina
Connecticut	Nevada	Tennessee
District of Columbia	New Jersey	Texas
Florida	New Mexico	Utah
Georgia	New York	Vermont (High Rate, High Point law)
Illinois, including the Cook County and Chicago ordinances	North Carolina	Wisconsin
Indiana	Ohio, including Cleveland Heights ordinance
Kentucky	Oklahoma

C. Anti-Predatory

Several states have laws that do not create a separate class of high cost or higher-priced mortgage loans, but set APR or finance charge ceilings and may also set forth similar anti-predatory lending restrictions as found in high cost laws. Clayton tests for compliance with such laws in the following states:

· Minnesota (Mortgage Originator and Service Licensing Act)

· Puerto Rico (Office Regulation 5722)

· Texas (Texas Finance Code)

· West Virginia (Residential Mortgage Lender, Broker and Servicer Act).

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D. Borrower’s Interest

Clayton uses a module that reports to the client the factors that the client can weigh to determine whether or not the loan is in the borrower’s interest, and also makes a mathematical determination as to whether or not there is at least one benefit. This module is only used in the following states, where the laws or releases by the regulators provide an indication of some standards that can be applied.

Borrower’s Interest
Maine	Ohio	South Carolina
Massachusetts	Rhode Island

E. Consumer Protection

Several states have laws that neither create a separate class of high cost or higher-priced mortgagee loan, nor impose a ceiling on the overall fees or APR, but nonetheless contain requirements and restrictions on mortgage loans that may impact the assignee or the lien. Clayton tests for compliance with such laws, including late charge and prepayment penalty provisions, in the following states and municipalities:

Consumer Protection
Alabama (the “Mini-code”)	Nebraska (Mortgage Bankers Registration and Licensing Act and the Installment Loan Act)
Hawaii (Financial Services Loan Company Act)	Nevada (AB 440
Idaho (Residential Mortgage Practices Act)	Ohio (Consumer Sales Practices Act; whether the loan is in Summit County)
Illinois (both versions of the Cook County Predatory Lending Database; Illinois Residential Mortgage Licensing Act)	Texas (Article XVI, Section 50(a)(6) of the Texas Constitution)
Iowa (Consumer Credit Code)	Utah (Consumer Credit Code)
Kansas (Consumer Credit Code)	Virginia (Mortgage Lender and Broker Act)
Kentucky (HB 552)	Washington (Consumer Loan Act and Responsible Mortgage Lending Act)
Maryland (DLLR Regulations, Commercial Law)	West Virginia (Consumer Credit Protection Act)
Massachusetts (Attorney General regulations)	Wyoming (Residential Mortgage Practices Act)
Michigan (Consumer Mortgage Protection Act)

See above for additional details on Consumer Protection Laws and the specific components of the aforementioned Consumer Protection laws that are evaluated as part of the Clayton Compliance Review Scope.

F. Texas Equity

In addition to identifying whether Texas refinances are cash out transactions subject to the Texas Constitution Article 16 Section 50(a)(6) requirements, Clayton reviews the title report to confirm prior loans being refinanced are continuous purchase money and not (a)(6) loans. In the event a loan is determined to be a Texas Home Equity loan, the underwriter reviews the loan images to confirm the loan meets the Texas requirements including maximum LTV/CLTV, 3% fee cap, product restrictions and the required disclosures were provided to the borrower in accordance with required timelines.

HOF 2019-3 Due Diligence Narrative Report Page | 21 October 31, 2019

GSE Testing

Clayton can review loans to determine whether they comply with Fannie Mae’s and Freddie Mac’s Points and Fees threshold tests. These fee limitations of 5% for all loans with application dates prior to 1/10/2014 were reduced to 3% on Primary and Second Homes for applications on or after 1/10/2014. If requested, loans can be reviewed to determine whether the loan is a residential mortgage transaction ineligible for delivery due to its APR or fees exceeding the HOEPA thresholds. Clayton offers Lender Letter and non-traditional mortgage testing for Fannie Mae. (Note: Fannie Mae requires a non-disclosure agreement between the client and Fannie Mae for Clayton to report these results.)

Disclaimer

Please be advised that Clayton has not determined whether the Loans comply with federal, state or local laws, constitutional provisions, regulations or ordinances, including, but not limited to, licensing and general usury laws that set rate and/or fee limitations, unless listed above. Clayton’s review is focused on issues that raise concerns for secondary market investors and other assignees, based on potential for assignee liability, an adverse impact on the lien, and regulatory, litigation and headline risk. Clayton’s review is not designed to fully test a lender’s compliance with all applicable disclosure and licensing requirements. Furthermore, the findings reached by Clayton are dependent upon its receiving complete and accurate data regarding the Loans from loan originators and other third parties. Please be further advised that Clayton and its employees do not engage in the practice of law, and the findings set forth in the reports prepared by Clayton do not constitute legal advice or opinions.

© 2019 Clayton Services LLC. All rights reserved.

This material is confidential and may not be copied, used, or distributed without the written permission of Clayton Services LLC

HOF 2019-3 Due Diligence Narrative Report Page | 22 October 31, 2019

EX-99.2

Exhibit 99.2 - Schedule 1

Client Name:	HOF 2019-3
Client Project Name:	HOF 2019-3
Start - End Dates:	9/26/2016 - 6/5/2019
Deal Loan Count:	8
Conditions Report 2.0
Loans in Report:	8
Loans with Conditions:	8

0 - Total Active Conditions
25 - Total Satisfied Conditions
	6 - Credit Review Scope
		1 - Category: Application
		1 - Category: Assets
		1 - Category: Credit/Mtg History
		1 - Category: DTI
		1 - Category: Income/Employment
		1 - Category: Legal Documents
	1 - Property Valuations Review Scope
		1 - Category: Appraisal
	18 - Compliance Review Scope
		1 - Category: Ability to Repay/Qualified Mortgage
		1 - Category: Documentation
		16 - Category: TILA/RESPA Integrated Disclosure
15 - Total Waived Conditions
	6 - Credit Review Scope
		1 - Category: Application
		1 - Category: Assets
		4 - Category: Terms/Guidelines
	9 - Compliance Review Scope
		1 - Category: Federal Consumer Protection
		1 - Category: State Rate Spread
		7 - Category: TILA/RESPA Integrated Disclosure
©2019 Clayton Services LLC. All rights reserved. Ownership and use of this report is governed by the legal agreement between Clayton and the party for which it was prepared. Any use not expressly authorized by such agreement, including reliance on this report by anyone other than such party, is prohibited.

Client Name:	HOF 2019-3
Client Project Name:	HOF 2019-3
Start - End Dates:	9/26/2016 - 6/5/2019
Deal Loan Count:	8
Conditions Report 2.0
Loans in Report:	8
Loans with Conditions:	8

Loan Number

Original Principal Balance

State

Initial Lender ATR/QM Status

Loan Level ATR/QM Status

Initial Securitization Overall Loan Grade

Final Securitization Overall Loan Grade

Initial Securitization Credit Loan Grade

Final Securitization Credit Loan Grade

Initial Securitization Property Valuations Loan Grade

Final Securitization Property Valuations Loan Grade

Initial Securitization Compliance Loan Grade

Final Securitization Compliance Loan Grade

Initial S&P Overall Loan Grade

Final S&P Overall Loan Grade

Initial S&P Credit Loan Grade

Final S&P Credit Loan Grade

Initial S&P Property Valuations Loan Grade

Final S&P Property Valuations Loan Grade

Initial S&P Compliance Loan Grade

Final S&P Compliance Loan Grade

Condition Category

Condition Sub Category

Condition Status

Initial Securitization Condition Grade

Final Securitization Condition Grade

Initial S&P Condition Grade

Final S&P Condition Grade

Condition Code

Condition Description

Condition Material Indicator

Initial Comments

Client/Seller Response Comments

Conclusion Comments

TRID Error Type

Cure Method

Compensating Factors

3113002866

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

D

A

B

A

A

A

D

A

D

A

B

A

A

A

D

A

Compliance

Ability to Repay/Qualified Mortgage

Satisfied

D

A

D

A

CMPATRQM3220

TILA - Loan subject to Ability to Repay/Qualified Mortgage rule; the loan file is missing documents to complete the ATR/QM review and render an accurate ATR/QM status.

No

Loan subject to Ability to Repay/Qualified Mortgage rule; the loan file is missing documents to complete the ATR/QM review and render an accurate ATR/QM status due to missing evidence of taxes and HOA fees for XXX and XXX to support expense listed on 1003 and included in DTI.

9.28.16 - lender provided taxes and HOA fees for XXX and XXX

9.28.16 - condition satisfied.

(No Data)

(No Data)

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  766 credit score; minimum required is 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI is 10.73%; guideline maximum is 50%. CFCFS1734: Borrower has significant time at current job - Clayton Comments:  Borrower has been XXX in same business for over 6 years.

3113002866

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

D

A

B

A

A

A

D

A

D

A

B

A

A

A

D

A

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

B

A

B

A

CMPTRID3730

TRID - Error #2 discovered on Closing Disclosure

No

Non numeric clerical error CD: 09/XX/2016-1, CD: 09/XX/2016-1, Section: Closing Information, Field: Street Address, Value: XXX does not match Security Interest Street Address, Value: XXX

10/3/16 - Post Close CD dated 10/3/16 has the correct address, XXX.

10/3/16 - Exception satisfied.

(No Data)

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  766 credit score; minimum required is 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI is 10.73%; guideline maximum is 50%. CFCFS1734: Borrower has significant time at current job - Clayton Comments:  Borrower has been XXX in same business for over 6 years.

3113002866

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

D

A

B

A

A

A

D

A

D

A

B

A

A

A

D

A

Credit

DTI

Satisfied

B

A

B

A

CRDDTI2540

Missing verification of some or all components of non-subject PITI

No

Missing evidence of taxes and HOA fees for XXX and XXX to support expense listed on 1003 and included in DTI.

9.28.16 - lender provided taxes and HOI, still need HOA. 9.28.16 - lender provided HOA for XXX and XXX to support expense listed on 1003 and included in DTI.

9.28.16 - condition remains.9.28.16 - condition satisfied.

(No Data)

(No Data)

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  766 credit score; minimum required is 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI is 10.73%; guideline maximum is 50%. CFCFS1734: Borrower has significant time at current job - Clayton Comments:  Borrower has been XXX in same business for over 6 years.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

State Rate Spread

Waived

B

B

B

B

CMPSRS2051

CA Higher-Priced Loan

No

Test APR is 6.550% versus CA higher priced loan Benchmark rate of 4.640% for a variance of 1.910% exceeding the CA higher priced loan rate spread trigger of 1.500%.

10/16/2018-  Client requested to waived.

10/16/2018- Waiver applied.

(No Data)

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID4074

TRID - CD: The Minimum Payment as disclosed in second column on the Projected Payments section of the Final Closing Disclosure which does not match Clayton's calculated minimum payment for the second column as based on the Note terms

No

Final CD dated 05.XX.2018 The Minimum Payment as disclosed in second column in the Projected Payments section does not match Clayton's calculated minimum payment for the second column as based on the Note terms, CD disclosed from Band 2: ($2307.00) and Clayton disclosed from Band 2: ($2000.09).

9/24/2018: Lender provided PCCD dated 7/XX/2018 with the correct minimum payment and total minimum payment for all columns in the Projected Payments section and a letter of explanation to the borrower.

9/24/2018: Exception satisfied. However, exception CMPTRID3940 generated as a result of entering the PCCD.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID4075

TRID - CD: The Minimum Payment as disclosed in third column on the Projected Payments section of the Final Closing Disclosure which does not match Clayton's calculated minimum payment for the third column as based on the Note terms

No

Final CD dated 05.XX.2018 The Minimum Payment as disclosed in third column in the Projected Payments section does not match Clayton's calculated minimum payment for the third column as based on the Note terms, CD disclosed from Band 3: ($2009.00) and Clayton disclosed from Band 3: ($2000.09).

9/24/2018: Lender provided PCCD dated 7/XX/2018 with the correct minimum payment and total minimum payment for all columns in the Projected Payments section and a letter of explanation to the borrower.

9/24/2018: Exception satisfied. However, exception CMPTRID3940 generated as a result of entering the PCCD.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID4076

TRID - CD: The Minimum Payment as disclosed in fourth column on the Projected Payments section of the Final Closing Disclosure which does not match Clayton's calculated minimum payment for the fourth column as based on the Note terms

No

Final CD dated 05.XX.2018 The Minimum Payment as disclosed in fourth column in the Projected Payments section does not match Clayton's calculated minimum payment for the fourth column as based on the Note terms, CD disclosed from Band 4: ($2009.00) and Clayton disclosed from Band 4: ($2000.09).

9/24/2018: Lender provided PCCD dated 7/XX/2018 with the correct minimum payment and total minimum payment for all columns in the Projected Payments section and a letter of explanation to the borrower.

9/24/2018: Exception satisfied. However, exception CMPTRID3940 generated as a result of entering the PCCD.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID4082

TRID - CD: The Total Minimum Payment as disclosed in second column on the Projected Payments section of the Final Closing Disclosure which does not match Clayton's calculated total minimum payment for the second column as based on the Note terms

No

Final CD dated 05.XX.2018 The Total Minimum Payment as disclosed in second column in the Projected Payments section does not match Clayton's calculated Total minimum payment for the second column as based on the Note terms, CD disclosed from Band 2: ($2980.00) and Clayton disclosed from Band 2: ($2673.35).

9/24/2018: Lender provided PCCD dated 7/XX/2018 with the correct minimum payment and total minimum payment for all columns in the Projected Payments section and a letter of explanation to the borrower.

9/24/2018: Exception satisfied. However, exception CMPTRID3940 generated as a result of entering the PCCD.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID4083

TRID - CD: The Total Minimum Payment as disclosed in third column on the Projected Payments section of the Final Closing Disclosure which does not match Clayton's calculated total minimum payment for the third column as based on the Note terms

No

Final CD dated 05.XX.2018 The Total Minimum Payment as disclosed in third column in the Projected Payments section does not match Clayton's calculated Total minimum payment for the third column as based on the Note terms, CD disclosed from Band 3: ($2682.00) and Clayton disclosed from Band 3: ($2673.35).

9/24/2018: Lender provided PCCD dated 7/XX/2018 with the correct minimum payment and total minimum payment for all columns in the Projected Payments section and a letter of explanation to the borrower.

9/24/2018: Exception satisfied. However, exception CMPTRID3940 generated as a result of entering the PCCD.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID4084

TRID - CD: The Total Minimum Payment as disclosed in fourth column on the Projected Payments section of the Final Closing Disclosure which does not match Clayton's calculated total minimum payment for the fourth column as based on the Note terms

No

Final CD dated 05.XX.2018 The Total Minimum Payment as disclosed in fourth column in the Projected Payments section does not match Clayton's calculated Total minimum payment for the fourth column as based on the Note terms, CD disclosed from Band 4: ($2682.00) and Clayton disclosed from Band 4: ($2673.35).

9/24/2018: Lender provided PCCD dated 7/XX/2018 with the correct minimum payment and total minimum payment for all columns in the Projected Payments section and a letter of explanation to the borrower.

9/24/2018: Exception satisfied. However, exception CMPTRID3940 generated as a result of entering the PCCD.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

N/A

B

N/A

B

CMPTRID3938

TRID - CD: The max payment as stated in the CD Loan Terms section does not match the highest possible payment noted within the CD Projected Payments section and/or, if applicable, the AP Table

No

The max payment value of $4162 as stated in the Loan Terms section of PCCD 9/XX/2018 does not match the highest possible payment of $4146 as noted within the CD Projected Payments section. Provide a post close CD with correction to the Loan Terms section and a letter of explanation to the borrower.

7.3.19 - Client provided PCCD dated 9/XX/18 correcting Loan terms section, LOX, and proof of delivery to borrower.

7.3.19 - Exception satisfied.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461205702

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

N/A

B

N/A

B

CMPTRID3940

TRID - CD: The year in which the max payment can occur as stated in the Loan Terms section does not match the year range associated with the highest possible payment in the Projected Payments section

No

On PCCD 7/XX/2018, The year in which the max payment can occur as stated in the Loan Terms section does not match the Clayton calculation. The CD discloses the max payment of $4162 in year 7 and the Clayton calculation is $4,146  in year 8-30. Provide a pose close CD with the correction and a letter of explanation to the borrower.

10/19/2018: Lender provided post close CD dated 9/XX/2018 correcting the max payment year and value in the Projected Payments section and a letter of explanation to borrower.

10/19/2018: Exception satisfied. However, exception CMPTRID3938 generated as a result.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 745 is 105 points higher than the required score of 640. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 38.13% is 11.87% lower than the maximum DTI of 50%. CFCFS1737: LTV below guideline requirements - Clayton Comments:  85% LTV is 5% lower than the maximum LTV of 90%.

4461206452

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

Compliance

Documentation

Satisfied

D

A

D

A

CMPDOC3274

Mortgage/Deed in file is incomplete

No

Missing the legal description to the mortgage.  Unable to determine if the mortgage legal matches the title legal.

09/25/2018  Lender provided the legal description to the Mortgage.

09/25/2018  Exception satisfied.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  Primary borrower and co-borrower each employed 10 years in same profession. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI of 19.99% is 30.01 points below the maximum permitted for investment properties of 50%. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Cash reserves are $238,323.03; minimum required is $51,743.86 (12 months for subject loan, and 2 months each for 4 additional properties owned).

4461206452

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

Credit

Application

Waived

B

B

B

B

CRDAPP130

Application is incomplete

No

1) File contains discrepancy due to subject transaction originated as an investor property, however, the appraisal states the occupant is owner. Lender to provide explanation/clarification. 2) Lease provided for subject property is noted as XXX, however, the file documents note the subject address as XXX. Lender to provide explanation/clarification.

10/16/2018- Client requested to waived.

10/16/2018- Waiver applied.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  Primary borrower and co-borrower each employed 10 years in same profession. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI of 19.99% is 30.01 points below the maximum permitted for investment properties of 50%. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Cash reserves are $238,323.03; minimum required is $51,743.86 (12 months for subject loan, and 2 months each for 4 additional properties owned).

4461206452

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

Credit

Assets

Satisfied

D

A

D

A

CRDAST2354

Asset Verification In File is Incomplete Per Requirements

No

Missing evidence of borrower's receipt of liquidated funds from borrower's verified retirement and/or investment accounts for cash to close of $22,522.16, required per Client guidelines.

10/4/2018- Lender provided Final Settlement statement reflecting that borrower getting cash back of $1,370.59

10/4/2018- Exception satisfied.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  Primary borrower and co-borrower each employed 10 years in same profession. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI of 19.99% is 30.01 points below the maximum permitted for investment properties of 50%. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Cash reserves are $238,323.03; minimum required is $51,743.86 (12 months for subject loan, and 2 months each for 4 additional properties owned).

4461206452

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

Credit

Credit/Mtg History

Satisfied

B

A

B

A

CRDCRMH193

Length of mortgage/rental history in file does not meet guideline requirement

No

Missing previous 12 months mortgage payment history from XXX acct #XXX for XXX. Liability is not reporting on the credit report. Client guidelines require review of all properties owned by borrowers to verify 0x30 for previous 12 months.

09/25/2018  Lender provided the credit report that shows the Lender as XXX of which matches the mortgage statement balance for XXX @ 0 x 30 for 53 months.

09/25/2018  Exception satisfied.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  Primary borrower and co-borrower each employed 10 years in same profession. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI of 19.99% is 30.01 points below the maximum permitted for investment properties of 50%. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Cash reserves are $238,323.03; minimum required is $51,743.86 (12 months for subject loan, and 2 months each for 4 additional properties owned).

4461206452

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

Credit

Income/Employment

Satisfied

B

A

B

A

CRDINC150

Income docs do not meet guidelines

No

Missing signatures on borrower's 2016 personal and 1120S tax returns, and 2017 P&L statement for XXX, required per Client guidelines when XXX income utilized for qualifying income.

10/16/2018- Client requested to waived. 03/14/2019 Lender provided signed documentation.

10/16/2018- Waiver applied.03/14/2019  Exception satisfied.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  Primary borrower and co-borrower each employed 10 years in same profession. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI of 19.99% is 30.01 points below the maximum permitted for investment properties of 50%. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Cash reserves are $238,323.03; minimum required is $51,743.86 (12 months for subject loan, and 2 months each for 4 additional properties owned).

4461206452

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

Credit

Legal Documents

Satisfied

D

A

D

A

CRDLGL2864

Copy of Mortgage/Deed in file is incomplete

No

Missing the legal description to the mortgage.  Unable to determine if the mortgage legal matches the title legal.

09/25/2018  Lender provided the legal description to the Mortgage.

09/25/2018  Exception satisfied.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  Primary borrower and co-borrower each employed 10 years in same profession. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI of 19.99% is 30.01 points below the maximum permitted for investment properties of 50%. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Cash reserves are $238,323.03; minimum required is $51,743.86 (12 months for subject loan, and 2 months each for 4 additional properties owned).

4461206452

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

Credit

Terms/Guidelines

Waived

B

B

B

B

CRDTER109

Cash Out Amount Exceeds Guidelines

No

Cash out of $403,766.16 for payoff of non-subject mortgage exceeds Client guideline maximum cash out permitted of $250,000.

09/25/2018  Lender provided the approved exception form noting compensating factors including 6 months reserves, low DTI, and years on job. The approved exception noted however exception remains. 10/16/2018- Client requested to waived.

10/16/2018- Waiver applied.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  Primary borrower and co-borrower each employed 10 years in same profession. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI of 19.99% is 30.01 points below the maximum permitted for investment properties of 50%. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Cash reserves are $238,323.03; minimum required is $51,743.86 (12 months for subject loan, and 2 months each for 4 additional properties owned).

4461206452

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

Property Valuations

Appraisal

Satisfied

C

A

C

A

PRVAAPPR169

Appraisal includes one or more issue(s)

No

The appraisal was transferred which does not meet client guidelines stating appraisals must be ordered through lender's approved XXX

09/25/2018  Lender provided the Lender approved appraisal transfer dated 4/23/2018.

09/25/2018  Exception satisfied.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  Primary borrower and co-borrower each employed 10 years in same profession. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI of 19.99% is 30.01 points below the maximum permitted for investment properties of 50%. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Cash reserves are $238,323.03; minimum required is $51,743.86 (12 months for subject loan, and 2 months each for 4 additional properties owned).

4461212005

XXXXXX

XXXXXX

(No Data)

ATR/QM: Not Applicable

B

B

B

B

A

A

A

A

B

B

B

B

A

A

A

A

Credit

Terms/Guidelines

Waived

B

B

B

B

CRDTER3124

Loan documents do not meet guideline requirements

No

Guidelines require 3 credit reference letters translated into English with a 24-month history.  Only 12 month provided.

8.15.19 - Client accepted non-material exception

8.15.19 - Final Clayton grade B

(No Data)

Not Applicable

CFCFS1736: Significant time at current residence - Clayton Comments:  borrower has rented current primary 8 years. CFCFS1734: Borrower has significant time at current job - Clayton Comments:  borrower has been with current job 8 years. CFCFS2854: Significant time in profession - Clayton Comments:  borrower has been with current profession 8 years.

4461213367

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID5023

TRID  CD:  The Minimum Payment disclosed in at least one column of the Final Closing Disclosure does not match the Minimum Payment that Clayton calculates based upon the Note Terms

No

Numeric Material Error CD: 12/XX/2018-1 - projected payment minimum payment for Band 2, 3, and 4 incorrect based on the ARM Note terms.

6.4.19 - Client provided PCCD dated 12/XX/18 correcting projected payment section.

6.4.19 - Exception satisfied.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score 709 is 29 points higher than the required score of 680. CFCFS2854: Significant time in profession - Clayton Comments:  Borrower has been in his profession for 9 years.

4461213367

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID5033

TRID - CD: The Total Minimum Payment disclosed in at least one column of the Projected Payments section of the Final Closing Disclosure does not match the Total Minimum Payment that Clayton calculates.

No

Numeric Material Error CD: 12/XX/2018-1 - projected payment minimum payment for Band 2, 3, and 4 incorrect based on the ARM Note terms.

6.4.19 - Client provided PCCD dated 12/XX/18 correcting projected payment section.

6.4.19 - Exception satisfied.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score 709 is 29 points higher than the required score of 680. CFCFS2854: Significant time in profession - Clayton Comments:  Borrower has been in his profession for 9 years.

4461213367

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Waived

B

B

B

B

CMPTRID4352

TRID - CD: At least one section contains formatting that does not comply with the Regulation

No

Non Numeric ErrorCD 12/X/18 and 12/XX/18 - Loan costs - Section B - broker credit report does not list who fee is payable to.

6.4.19 - Client provided PCCD dated 12/XX/18.   Loan costs - Section B - broker credit report does not list who fee is payable to.7.30.19 Client has accepted non-material exception

7.30.19 Final Clayton grade B

Hybrid

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score 709 is 29 points higher than the required score of 680. CFCFS2854: Significant time in profession - Clayton Comments:  Borrower has been in his profession for 9 years.

4461213367

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Waived

B

B

B

B

CMPTRID4463

TRID - Assumption selection on the CD does not match the clause in the mortgage.

No

Non Numeric ErrorCD 12/XX/18 - Loan disclosure - Assumption does not match note/product.

6.4.19 - Client provided PCCD dated 12/XX/18.   Loan disclosure - Assumption does not match note/product.7.30.19 Client has accepted non-material exception

7.30.19 Final clayton grade B

Non-Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score 709 is 29 points higher than the required score of 680. CFCFS2854: Significant time in profession - Clayton Comments:  Borrower has been in his profession for 9 years.

4461213367

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Credit

Assets

Waived

B

B

B

B

CRDAST3078

Insufficient # of months cash reserves for PITI per guideline requirements

No

Short the required 6 months reserves $3,740.48 x 6=$22,442.88.  $22,156.20 documented 5.92 months

7.30.19 Client has accepted non-material exception

7.30.19 Final Clayton Grade B

(No Data)

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score 709 is 29 points higher than the required score of 680. CFCFS2854: Significant time in profession - Clayton Comments:  Borrower has been in his profession for 9 years.

4461215818

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

ATR/QM: Exempt

C

B

C

B

A

A

C

B

C

B

C

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID5023

TRID  CD:  The Minimum Payment disclosed in at least one column of the Final Closing Disclosure does not match the Minimum Payment that Clayton calculates based upon the Note Terms

No

Numeric Material ErrorCD 3/X/19 and 3/XX/19 - Projected Payments section:  Minimum Payments  from Band 2 disclosed as $6359.00; Value from Band 2 calculated to be: $5122.00 per note terms.Minimum Payments  from Band 3 disclosed as $5224.00; Value from Band 3 calculated to be: $5122.00 per note terms.Minimum Payments  from Band 4 disclosed as $5224.00; Value from Band 4 calculated to be: $5122.00 per note terms.

7.3.19 - Client provided PCCD dated 6/XX/19 correcting projected payment section.

7.3.19 - Exception satisfied

Numeric

Not Applicable

CFCFS1734: Borrower has significant time at current job - Clayton Comments:  The Borrower has been XXX for 7 years CFCFS1739: Postive mortgage payment history - Clayton Comments:  Mortgage on subject property has been paid as agreed for 16 months (12 months required per guidelines CFCFS1737: LTV below guideline requirements - Clayton Comments:  Current LTV of 77.14% below max allowable per guides of 80%. CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Minimum credit score for 2nd home Cash out transaction is 620 with current credit score at 696. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Current reserves at $178,706.67  with required reserves at $56,654.46. A surplus of $122,052.21.

4461215818

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

ATR/QM: Exempt

C

B

C

B

A

A

C

B

C

B

C

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID5033

TRID - CD: The Total Minimum Payment disclosed in at least one column of the Projected Payments section of the Final Closing Disclosure does not match the Total Minimum Payment that Clayton calculates.

No

Numeric Material ErrorCD 3/6/19 and 3/12/19 - Projected Payments section:  Total Minimum Payments  from Band 2 disclosed as $6359.00; Value from Band 2 calculated to be: $5122.00 per note terms.Total Minimum Payments  from Band 3 disclosed as $5224.00; Value from Band 3 calculated to be: $5122.00 per note terms.Total Minimum Payments  from Band 4 disclosed as $5224.00; Value from Band 4 calculated to be: $5122.00 per note terms.

7.3.19 - Client provided PCCD dated 6/18/19 correcting projected payment section.

7.3.19 - Exception satisfied

Numeric

Not Applicable

CFCFS1734: Borrower has significant time at current job - Clayton Comments:  The Borrower has been XXX for 7 years CFCFS1739: Postive mortgage payment history - Clayton Comments:  Mortgage on subject property has been paid as agreed for 16 months (12 months required per guidelines CFCFS1737: LTV below guideline requirements - Clayton Comments:  Current LTV of 77.14% below max allowable per guides of 80%. CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Minimum credit score for 2nd home Cash out transaction is 620 with current credit score at 696. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Current reserves at $178,706.67  with required reserves at $56,654.46. A surplus of $122,052.21.

4461215818

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

ATR/QM: Exempt

C

B

C

B

A

A

C

B

C

B

C

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Waived

B

B

B

B

CMPTRID4352

TRID - CD: At least one section contains formatting that does not comply with the Regulation

No

Non Numeric ErrorCD 3/X/19, 3/X/19 and 3/XX/19 - (1) Other costs - Section E - Intangible tax does not list who fee is payable to.(2) Other costs - section H - Mtg Doc Stamps does not list who fee is payable to.

7.3.19 - Client provided PCCD dated 6/XX/19.  (1) Other costs - Section E - Intangible tax does not list who fee is payable to.(2) Other costs - section H - Mtg Doc Stamps does not list who fee is payable to.

7/3/2019-Clayton final grade B

Hybrid

Not Applicable

CFCFS1734: Borrower has significant time at current job - Clayton Comments:  The Borrower has been XXX for 7 years CFCFS1739: Postive mortgage payment history - Clayton Comments:  Mortgage on subject property has been paid as agreed for 16 months (12 months required per guidelines CFCFS1737: LTV below guideline requirements - Clayton Comments:  Current LTV of 77.14% below max allowable per guides of 80%. CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Minimum credit score for 2nd home Cash out transaction is 620 with current credit score at 696. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Current reserves at $178,706.67  with required reserves at $56,654.46. A surplus of $122,052.21.

4461215818

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

ATR/QM: Exempt

C

B

C

B

A

A

C

B

C

B

C

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Waived

B

B

B

B

CMPTRID4463

TRID - Assumption selection on the CD does not match the clause in the mortgage.

No

Non Numeric ErrorCD 3/XX/19 - Loan disclosure - Assumption does not match Note/Rider.

7.3.19 - Client provided PCCD dated 6/XX/19.  Loan disclosure - Assumption does not match Note/Rider.

7/3/2019-Clayton final grade B

Non-Numeric

Not Applicable

CFCFS1734: Borrower has significant time at current job - Clayton Comments:  The Borrower has been XXX for 7 years CFCFS1739: Postive mortgage payment history - Clayton Comments:  Mortgage on subject property has been paid as agreed for 16 months (12 months required per guidelines CFCFS1737: LTV below guideline requirements - Clayton Comments:  Current LTV of 77.14% below max allowable per guides of 80%. CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Minimum credit score for 2nd home Cash out transaction is 620 with current credit score at 696. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Current reserves at $178,706.67  with required reserves at $56,654.46. A surplus of $122,052.21.

4461215818

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

ATR/QM: Exempt

C

B

C

B

A

A

C

B

C

B

C

B

A

A

C

B

Credit

Application

Satisfied

C

A

C

A

CRDAPP4625

The orig file does not contain a third party fraud report

No

File is missing the 3rd party fraud report

06/19/2019  lender provided FraudGuard.06/19/2019  Clayton reviewed FraudGuard, dated 01/03/2019.  Exception satisfied.

06/19/2019  Exception satisfied.

Not Applicable

Not Applicable

CFCFS1734: Borrower has significant time at current job - Clayton Comments:  The Borrower has been XXX for 7 years CFCFS1739: Postive mortgage payment history - Clayton Comments:  Mortgage on subject property has been paid as agreed for 16 months (12 months required per guidelines CFCFS1737: LTV below guideline requirements - Clayton Comments:  Current LTV of 77.14% below max allowable per guides of 80%. CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Minimum credit score for 2nd home Cash out transaction is 620 with current credit score at 696. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Current reserves at $178,706.67  with required reserves at $56,654.46. A surplus of $122,052.21.

4461215818

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

ATR/QM: Exempt

C

B

C

B

A

A

C

B

C

B

C

B

A

A

C

B

Credit

Terms/Guidelines

Waived

B

B

B

B

CRDTER3122

Loan documents do not meet guideline requirements

No

Note and ARM rider allow for assumption. Guides, Mortgage and Final CD do not allow for assumption.

7/3/2019-Client has accepted non-material compliance exception

7/3/2019-Clayton final grade B

(No Data)

Not Applicable

CFCFS1734: Borrower has significant time at current job - Clayton Comments:  The Borrower has been XXX for 7 years CFCFS1739: Postive mortgage payment history - Clayton Comments:  Mortgage on subject property has been paid as agreed for 16 months (12 months required per guidelines CFCFS1737: LTV below guideline requirements - Clayton Comments:  Current LTV of 77.14% below max allowable per guides of 80%. CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Minimum credit score for 2nd home Cash out transaction is 620 with current credit score at 696. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Current reserves at $178,706.67  with required reserves at $56,654.46. A surplus of $122,052.21.

4461217848

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID4038

TRID - CD: The Minimum Amount at First Payment Change on the AP Table of the Final Closing Disclosure does not match Claytons calculated Minimum Amount at First Payment Change

No

Numeric material error- CD: 03/XX/2019- AP Table - First Change Minimum Amount disclosed as $4,609.00, Review Calculates this to be $4,302.08 per Note terms.

6.20.19 - Client provided PCCD dated 6/XX/19 correcting AP table.

6.20.19 - Exception satisfied.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 799 is 119 points higher than the required score of 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 32.36% with maximum DTI of 50% allowable. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Reserves at $621,676.38. Required reserves $62,614.08.

4461217848

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID5023

TRID  CD:  The Minimum Payment disclosed in at least one column of the Final Closing Disclosure does not match the Minimum Payment that Clayton calculates based upon the Note Terms

No

Numeric material error-CD: 03/XX/2019 - Projected Payments section, Total Min Payments from Band 2 disclosed as $4609.00. Review calculates minimum payment for Band 2 as $4302.08 per note terms. Note discloses Minimum rate explicitly stated of 3.500%.

6.20.19 - Client provided PCCD dated 6/XX/19 correcting projected payments section.

6.20.19 - Exception satisfied.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 799 is 119 points higher than the required score of 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 32.36% with maximum DTI of 50% allowable. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Reserves at $621,676.38. Required reserves $62,614.08.

4461217848

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Satisfied

C

B

C

B

CMPTRID5033

TRID - CD: The Total Minimum Payment disclosed in at least one column of the Projected Payments section of the Final Closing Disclosure does not match the Total Minimum Payment that Clayton calculates.

No

Numeric material error -CD: 03/XX/2019 - Projected Payments section, Total Min Payments from Band 2 disclosed as $6.806.00. Review calculates total minimum payment for Band 2 as $6,499.32 per note terms. Note discloses Minimum rate explicitly stated of 3.500%.

6.20.19 - Client provided PCCD dated 6/XX/19 correcting projected payments section.

6.20.19 - Exception satisfied.

Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 799 is 119 points higher than the required score of 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 32.36% with maximum DTI of 50% allowable. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Reserves at $621,676.38. Required reserves $62,614.08.

4461217848

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Waived

B

B

B

B

CMPTRID3754

TRID - Error #3 discovered on Loan Estimate

No

Numeric Non Material ErrorLE 3/8/19 - Comparison section - "in 5 years" discloses Principal paid off as $106758.  Loan is IO for 10 years.  This should be $0.

7/3/2019-Client has accepted non-material compliance exception

7/3/2019-Clayton final grade B

(No Data)

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 799 is 119 points higher than the required score of 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 32.36% with maximum DTI of 50% allowable. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Reserves at $621,676.38. Required reserves $62,614.08.

4461217848

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Waived

B

B

B

B

CMPTRID4352

TRID - CD: At least one section contains formatting that does not comply with the Regulation

No

Non numeric error - CD 3/9/19 and  03/12/2019 Other Costs, Other, Home Warranty and NHD Report payee names missing.

6.20.19 - Client provided PCCD dated 6/18/19.  Other Costs, Other, Home Warranty and NHD Report payee names missing.7.3.19 - Client resent CD 6/18/19.  Other Costs, Other, Home Warranty and NHD Report payee names missing. 7/3/2019-Client has accepted non-material compliance exception.

7/3/2019-Clayton final grade B

Hybrid

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 799 is 119 points higher than the required score of 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 32.36% with maximum DTI of 50% allowable. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Reserves at $621,676.38. Required reserves $62,614.08.

4461217848

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Compliance

TILA/RESPA Integrated Disclosure

Waived

B

B

B

B

CMPTRID4463

TRID - Assumption selection on the CD does not match the clause in the mortgage.

No

CD 3/12/19 - Loan Disclosures - Assumption does not match Note/Rider.

6.20.19 - Client provided PCCD dated 6/XX/19.   Loan Disclosures - Assumption does not match Note/Rider.7.3.19 - Client resent CD 6/XX/19.   Loan Disclosures - Assumption does not match Note/Rider.

7/3/2019-Clayton final grade B

Non-Numeric

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 799 is 119 points higher than the required score of 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 32.36% with maximum DTI of 50% allowable. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Reserves at $621,676.38. Required reserves $62,614.08.

4461217848

XXXXXX

XXXXXX

Non-QM: Lender documented all ATR UW factors

Non-QM: Lender documented all ATR UW factors

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Credit

Terms/Guidelines

Waived

B

B

B

B

CRDTER3122

Loan documents do not meet guideline requirements

No

Note and ARM Rider support assumable loan. Per Guides, Mortgage and final CD the loan is not assumable.

7/3/2019-Client has accepted non-material compliance exception

7/3/2019-Clayton final grade B

(No Data)

Not Applicable

CFCFS1741: Credit score exceeds guidelines - Clayton Comments:  Median score of 799 is 119 points higher than the required score of 680. CFCFS1744: DTI below guideline requirement - Clayton Comments:  DTI 32.36% with maximum DTI of 50% allowable. CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  Reserves at $621,676.38. Required reserves $62,614.08.

5501799141

XXXXXX

XXXXXX

QM: Safe Harbor

QM: Safe Harbor

B

B

A

A

A

A

B

B

B

B

A

A

A

A

B

B

Compliance

Federal Consumer Protection

Waived

B

B

B

B

CMPFDCP4569

NMLS License verification found Loan Originator Name does not match ID but can identify that the LO is the same

No

Originator on loan docs has no middle name. NMLS has full middle name

5.7.19 - Client acknowledged exception.

5.7.19 - Exception acknowledged.

(No Data)

Not Applicable

CFCFS2854: Significant time in profession - Clayton Comments:  B1 has been in the same profession for 8 years and B2 10 years CFCFS1731: Verified cash reserves exceed guidelines - Clayton Comments:  $490,972.56 in verified post clsg reserves, or 72.17 months PITI. 18 months required. 12 months reserves required for loan amounts > $1,000,000 to $2,000,000 ($6803.17 X 12=$81.638.04) and 6 months for departing residence ($1968.84 X 6=$11,813.04)

Client Name:	HOF 2019-3
Client Project Name:	HOF 2019-3
Start - End Dates:	9/26/2016 - 6/5/2019
Deal Loan Count:	8
Conditions Report 2.0
Loans in Report:	8
Loans with Conditions:	8

Loan Number

TRID Indicator

Lender Application Date

Broker Application Date

Initial Securitization Overall Loan Grade

Final Securitization Overall Loan Grade

Initial Securitization Credit Loan Grade

Final Securitization Credit Loan Grade

Initial Securitization Property Valuations Loan Grade

Final Securitization Property Valuations Loan Grade

Initial Securitization Compliance Loan Grade

Final Securitization Compliance Loan Grade

Initial S&P Overall Loan Grade

Final S&P Overall Loan Grade

Initial S&P Credit Loan Grade

Final S&P Credit Loan Grade

Initial S&P Property Valuations Loan Grade

Final S&P Property Valuations Loan Grade

Initial S&P Compliance Loan Grade

Final S&P Compliance Loan Grade

Did Lender Acknowledge Exception at Origination

3113002866

Yes

XXXXXX

XXXXXX

D

A

B

A

A

A

D

A

D

A

B

A

A

A

D

A

(No Data)

4461205702

Yes

XXXXXX

XXXXXX

C

B

A

A

A

A

C

B

C

B

A

A

A

A

C

B

(No Data)

4461206452

Yes

XXXXXX

XXXXXX

D

B

D

B

C

A

D

A

D

B

D

B

C

A

D

A

(No Data)

4461212005

Yes

XXXXXX

XXXXXX

B

B

B

B

A

A

A

A

B

B

B

B

A

A

A

A

Not Applicable

4461213367

Yes

XXXXXX

XXXXXX

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

Yes

4461215818

Yes

XXXXXX

XXXXXX

C

B

C

B

A

A

C

B

C

B

C

B

A

A

C

B

No

4461217848

Yes

XXXXXX

XXXXXX

C

B

B

B

A

A

C

B

C

B

B

B

A

A

C

B

No

5501799141

Yes

XXXXXX

XXXXXX

B

B

A

A

A

A

B

B

B

B

A

A

A

A

B

B

Not Applicable

EX-99.2

Exhibit 99.2 - Schedule 2

Client Name:	HOF 2019-3
Client Project Name:	HOF 2019-3
Start - End Dates:	9/26/2016 - 6/5/2019
Deal Loan Count:	8
Loan Level Tape Compare Upload
Loans in Report	8

Loan Number	Borrower Last Name	Field	Tape Data	Reviewer Data
3113002866	XXXXX	Loan Doc Type	Alt Doc/Bank Statements	Full Doc
3113002866	XXXXX	DTI (Back)	XXXXX	XXXXX
4461205702	XXXXX	Loan Doc Type	Full Doc	Alt Doc
4461205702	XXXXX	DTI (Back)	XXXXX	XXXXX
4461205702	XXXXX	Lender ATR/QM Status	QM: Safe Harbor	Non-QM: Lender documented all ATR UW factors
4461205702	XXXXX	Representative Score	XXXXX	XXXXX
5501799141	XXXXX	Loan to Value	XXXXX	XXXXX
5501799141	XXXXX	Combined Loan to Value	XXXXX	XXXXX
5501799141	XXXXX	Qualifying DTI (Back)	XXXXX	XXXXX
©2019 Clayton Services LLC. All rights reserved. Ownership and use of this report is governed by the legal agreement between Clayton and the party for which it was prepared. Any use not expressly authorized by such agreement, including reliance on this report by anyone other than such party, is prohibited.

EX-99.2

Exhibit 99.2 - Schedule 3

Client Name:	HOF 2019-3
Client Project Name:	HOF 2019-3
Start - End Dates:	9/26/2016 - 6/5/2019
Deal Loan Count:	8
ATR QM Upload
Loans in Report:	8

Loan Number

Deal

Seller Loan Number

Original Principal Balance

State

Loan Level ATR/QM Status

Lender Provided ATR/QM Worksheet

Initial Lender ATR/QM Status

Application Date

Occupancy

Property Type

Number of Units

Loan Type

Exempt Loan Product Type

Exempt Loan Housing Agency

Community Housing Development

Credit Under Economic Stabilization Act Of 2008

Refinance Of Non-Standard Mortgage

Higher Priced Covered Transaction

State Prepay Exceptions

Loan Purpose

Loan Term Exceeds 30 Years

Interest Only Feature

Negative Amortization

Balloon Payment

Prepay Penalty Flag

Prepayment Penalty Type

Prohibited Prepayment Penalty

Exceeds Points And Fees

Exceeds DTI Limit

Lien Position

APR

QM Calculated DTI Adherence

QM Lenders DTI Adherence

QM Fee Adherence - Total Charges %

QM Fee Adherence - Lenders Fee %

Fannie Mae Eligible

Freddie Mac Eligible

VA Guaranty Eligible

FHA Insured Eligible

USDA Guarantee Eligible

Rural Housing Service Insured Eligible

QM - Expected Income Or Assets For DTI

QM - Current Employment Status For DTI

QM - Monthly Payment On Subject Loan For DTI

QM - Monthly Payment On Additional Loan For DTI

QM - Monthly Payment Mortgage Related Obligations

QM - Current Debt Obligations Alimony and Child Support for DTI

QM - Monthly DTI Ratio Or Residual Income

ATR - Guidelines Provided to Document Approach

ATR - Current And Expected Income And Assets

ATR - Current Employment Status

ATR - Mortgage Payment Obligation

ATR - Mortgage Payment on Simultaneous Transaction

ATR - Payment For Mortgage Related Obligations

ATR - Debt Obligations Including Alimony and Child Support

ATR - Monthly DTI Ratio or Residual Income

ATR - Consumer Credit History

ATR Lenders - DTI (Back)

ATR Calculated DTI (Back)

QM Lender Value DTI (Back)

QM Calculated DTI (Back)

Initial DTI (Back)

DTI Qualifying (Back)

Residual Income Analysis in File

Residual Income Guidelines

Did Loan Meet Guidelines

Residual Income Amount

Short Sale

Short Sale Date

Deed In Lieu

Deed In Lieu Date

QRM Flag

Borrower 1 Paystub Flag

Borrower 1 Paystub Number of Months

Borrower 2 Paystub Flag

Borrower 2 Paystub Number of Months

Borrower 3 Paystub Flag

Borrower 3 Paystub Number of Months

Borrower 4 Paystub Flag

Borrower 4 Paystub Number of Months

Borrower 1 W2 Flag

Borrower 1 W2 Number of Months

Borrower 2 W2 Flag

Borrower 2 W2 Number of Months

Borrower 3 W2 Flag

Borrower 3 W2 Number of Months

Borrower 4 W2 Flag

Borrower 4 W2 Number of Months

Borrower 1 Personal Tax Return Flag

Borrower 1 Personal Tax Return Number of Months

Borrower 2 Personal Tax Return Flag

Borrower 2 Personal Tax Return Number of Months

Borrower 3 Personal Tax Return Flag

Borrower 3 Personal Tax Return Number of Months

Borrower 4 Personal Tax Return Flag

Borrower 4 Personal Tax Return Number of Months

Borrower 1 Business Tax Return Flag

Borrower 1 Business Tax Return Number of Months

Borrower 2 Business Tax Return Flag

Borrower 2 Business Tax Return Number of Months

Borrower 3 Business Tax Return Flag

Borrower 3 Business Tax Return Number of Months

Borrower 4 Business Tax Return Flag

Borrower 4 Business Tax Return Number of Months

Borrower 1 Verbal VOE Flag

Borrower 1 Verbal VOE Number of Months

Borrower 2 Verbal VOE Flag

Borrower 2 Verbal VOE Number of Months

Borrower 3 Verbal VOE Flag

Borrower 3 Verbal VOE Number of Months

Borrower 4 Verbal VOE Flag

Borrower 4 Verbal VOE Number of Months

Borrower 1 Written VOE Flag

Borrower 1 Written VOE Number of Months

Borrower 2 Written VOE Flag

Borrower 2 Written VOE Number of Months

Borrower 3 Written VOE Flag

Borrower 3 Written VOE Number of Months

Borrower 4 Written VOE Flag

Borrower 4 Written VOE Number of Months

Borrower 1 P&L Flag

Borrower 1 P&L Number of Months

Borrower 2 P&L Flag

Borrower 2 P&L Number of Months

Borrower 3 P&L Flag

Borrower 3 P&L Number of Months

Borrower 4 P&L Flag

Borrower 4 P&L Number of Months

Borrower 1 Lease Agreement Flag

Borrower 1 Lease Agreement Number of Months

Borrower 2 Lease Agreement Flag

Borrower 2 Lease Agreement Number of Months

Borrower 3 Lease Agreement Flag

Borrower 3 Lease Agreement Number of Months

Borrower 4 Lease Agreement Flag

Borrower 4 Lease Agreement Number of Months

Equity Income Flag

Equity Income Amount

Equity Income Number of Months

DSCR with Rent Schedule Flag

DSCR with Lease Agreement Flag

DSCR %

Borrower 1 CPA Letter with Income Flag

Borrower 1 CPA Letter with Income Number of Months

Borrower 1 CPA Letter without Income Flag

Borrower 1 CPA Letter without Income Number of Months

Borrower 2 CPA Letter with Income Flag

Borrower 2 CPA Letter with Income Number of Months

Borrower 2 CPA Letter without Income Flag

Borrower 2 CPA Letter without Income Number of Months

Borrower 3 CPA Letter with Income Flag

Borrower 3 CPA Letter with Income Number of Months

Borrower 3 CPA Letter without Income Flag

Borrower 3 CPA Letter without Income Number of Months

Borrower 4 CPA Letter with Income Flag

Borrower 4 CPA Letter with Income Number of Months

Borrower 4 CPA Letter without Income Flag

Borrower 4 CPA Letter without Income Number of Months

Borrower 1 Personal Bank Statements Flag

Borrower 1 Personal Bank Statements Number of Months

Borrower 2 Personal Bank Statements Flag

Borrower 2 Personal Bank Statements Number of Months

Borrower 3 Personal Bank Statements Flag

Borrower 3 Personal Bank Statements Number of Months

Borrower 4 Personal Bank Statements Flag

Borrower 4 Personal Bank Statements Number of Months

Borrower 1 Business Bank Statements Flag

Borrower 1 Business Bank Statements Number of Months

Borrower 2 Business Bank Statements Flag

Borrower 2 Business Bank Statements Number of Months

Borrower 3 Business Bank Statements Flag

Borrower 3 Business Bank Statements Number of Months

Borrower 4 Business Bank Statements Flag

Borrower 4 Business Bank Statements Number of Months

Borrower 1 Award Letter Flag

Borrower 1 Award Letter Number of Months

Borrower 2 Award Letter Flag

Borrower 2 Award Letter Number of Months

Borrower 3 Award Letter Flag

Borrower 3 Award Letter Number of Months

Borrower 4 Award Letter Flag

Borrower 4 Award Letter Number of Months

Borrower 1 Offer Letter Flag

Borrower 1 Offer Letter Number of Months

Borrower 2 Offer Letter Flag

Borrower 2 Offer Letter Number of Months

Borrower 3 Offer Letter Flag

Borrower 3 Offer Letter Number of Months

Borrower 4 Offer Letter Flag

Borrower 4 Offer Letter Number of Months

Borrower 1 IRS Transcripts - Tax Returns Flag

Borrower 1 IRS Transcripts - Tax Returns Number of Months

Borrower 1 IRS Transcripts - W2s Flag

Borrower 1 IRS Transcripts - W2s Number of Months

Borrower 2 IRS Transcripts - Tax Returns Flag

Borrower 2 IRS Transcripts - Tax Returns Number of Months

Borrower 2 IRS Transcripts - W2s Flag

Borrower 2 IRS Transcripts - W2s Number of Months

Borrower 3 IRS Transcripts - Tax Returns Flag

Borrower 3 IRS Transcripts - Tax Returns Number of Months

Borrower 3 IRS Transcripts - W2s Flag

Borrower 3 IRS Transcripts - W2s Number of Months

Borrower 4 IRS Transcripts - Tax Returns Flag

Borrower 4 IRS Transcripts - Tax Returns Number of Months

Borrower 4 IRS Transcripts - W2s Flag

Borrower 4 IRS Transcripts - W2s Number of Months

3113002866

XXXXX

(No Data)

XXXXX

XXXXX

Non-QM: Lender documented all ATR UW factors

Present

Non-QM: Lender documented all ATR UW factors

XXXXX

Primary

SFR

1

Conventional

No

No

No

No

No

Yes

No

Purchase

No

No

No

No

No

(No Data)

(No Data)

No

No

1

5.5365

Yes

Yes

1.025

Unavailable

(No Data)

(No Data)

No

No

No

No

No

Yes

Yes

(No Data)

Yes

No

Yes

Yes

Documented

Documented

Documented

Not Applicable

Documented

Documented

Documented

Documented

10.75

10.73

10.75

11.1

10.67

10.73

No

No

(No Data)

236637.52

(No Data)

(No Data)

(No Data)

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

(No Data)

No

No

(No Data)

Yes

1

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

12

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

4461205702

XXXXX

(No Data)

XXXXX

XXXXX

Non-QM: Lender documented all ATR UW factors

Present

Non-QM: Lender documented all ATR UW factors

XXXXX

Primary

SFR

1

Conventional

No

No

No

No

(No Data)

Yes

No

Purchase

No

No

No

No

No

(No Data)

(No Data)

No

Yes

1

6.5495

No

No

1.343

Not Applicable

(No Data)

(No Data)

No

No

No

No

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

Yes

Documented

Documented

Documented

Not Applicable

Documented

Documented

Documented

Documented

37.16

38.13

0

43.67

38.13

38.13

No

No

(No Data)

5877.79

No

(No Data)

No

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

999

No

(No Data)

No

(No Data)

No

(No Data)

Yes

999

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

2

No

(No Data)

No

(No Data)

No

(No Data)

Yes

24

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

4461206452

XXXXX

(No Data)

XXXXX

XXXXX

ATR/QM: Not Applicable

(No Data)

(No Data)

XXXXX

Investor

Low Rise Condo (1-4)

1

Conventional

No

No

(No Data)

(No Data)

(No Data)

Yes

(No Data)

Cashout Refi

No

No

No

No

Yes

1% of amt prepaid > 20% OPB

(No Data)

No

Yes

1

7.1164

Yes

No

0.8

(No Data)

(No Data)

(No Data)

No

No

No

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

0

19.04

0

19.04

19.04

19.99

(No Data)

(No Data)

(No Data)

27897.89

No

(No Data)

No

(No Data)

No

Yes

1

Yes

1

No

(No Data)

No

(No Data)

Yes

24

Yes

24

No

(No Data)

No

(No Data)

Yes

12

Yes

12

No

(No Data)

No

(No Data)

Yes

12

Yes

12

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

1

Yes

1

No

(No Data)

No

(No Data)

Yes

999

No

(No Data)

No

(No Data)

No

(No Data)

Yes

999

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

12

No

(No Data)

Yes

12

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

4461212005

XXXXX

(No Data)

XXXXX

XXXXX

ATR/QM: Not Applicable

(No Data)

(No Data)

XXXXX

Second Home

Mixed Use

1

Conventional

No

No

(No Data)

(No Data)

(No Data)

No

(No Data)

Purchase

No

No

No

No

No

(No Data)

(No Data)

No

Yes

1

6.4504

Yes

No

0

(No Data)

(No Data)

(No Data)

No

No

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

0

21.67

0

21.67

21.67

21.87

(No Data)

(No Data)

(No Data)

12878.79

No

(No Data)

No

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

(No Data)

No

No

(No Data)

Yes

33

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

4461213367

XXXXX

(No Data)

XXXXX

XXXXX

Non-QM: Lender documented all ATR UW factors

Present

Non-QM: Lender documented all ATR UW factors

XXXXX

Primary

Detached PUD

1

Conventional

No

No

No

No

(No Data)

Yes

No

Purchase

No

No

No

No

No

(No Data)

(No Data)

No

Yes

1

7.4056

No

No

1.36

Not Applicable

(No Data)

(No Data)

No

No

No

No

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

Yes

Documented

Documented

Documented

Not Applicable

Documented

Documented

Documented

Documented

51.58

46.78

51.58

49.81

46.78

46.78

Yes

Yes

Yes

9484.12

No

(No Data)

No

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

24

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

12

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

4461215818

XXXXX

(No Data)

XXXXX

XXXXX

ATR/QM: Exempt

Present

Non-QM: Lender documented all ATR UW factors

XXXXX

Second Home

SFR

1

Conventional

No

No

No

No

(No Data)

Yes

No

Cashout Refi

No

No

No

No

No

(No Data)

(No Data)

No

No

1

6.9094

Yes

Yes

1.141

Not Applicable

(No Data)

(No Data)

No

No

No

No

Yes

No

No

(No Data)

No

No

No

Yes

Documented

Documented

Documented

Not Applicable

Documented

Documented

Documented

Documented

41.13

41.13

41.13

41.13

41.13

41.13

Yes

Yes

Yes

14356.63

No

(No Data)

No

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

24

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

(No Data)

No

No

(No Data)

Yes

1

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

24

No

(No Data)

No

(No Data)

No

(No Data)

Yes

24

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

4461217848

XXXXX

(No Data)

XXXXX

XXXXX

Non-QM: Lender documented all ATR UW factors

Present

Non-QM: Lender documented all ATR UW factors

XXXXX

Primary

SFR

1

Conventional

No

No

No

No

(No Data)

No

No

Purchase

Yes

Yes

No

No

No

(No Data)

(No Data)

No

No

1

6.2023

Yes

Yes

1.357

Not Applicable

(No Data)

(No Data)

No

No

No

No

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

(No Data)

Yes

Documented

Documented

Documented

Not Applicable

Documented

Documented

Documented

Documented

32.56

32.36

32.56

33.25

26.49

28.76

Yes

Yes

Yes

26758.51

No

(No Data)

No

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

12

No

(No Data)

No

(No Data)

No

(No Data)

Yes

12

No

(No Data)

No

(No Data)

No

(No Data)

Yes

12

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

(No Data)

No

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

12

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

5501799141

XXXXX

5501799141

XXXXX

XXXXX

QM: Safe Harbor

Present

QM: Safe Harbor

XXXXX

Primary

SFR

1

Conventional

No

No

No

No

(No Data)

No

No

Purchase

No

No

No

No

No

(No Data)

(No Data)

No

No

1

4.9202

Yes

Yes

1.454

Not Applicable

(No Data)

(No Data)

No

No

No

No

Yes

Yes

Yes

(No Data)

Yes

Yes

Yes

(No Data)

(No Data)

(No Data)

(No Data)

Not Applicable

(No Data)

(No Data)

(No Data)

(No Data)

37.67

37.72

37.67

37.72

37.72

37.72

No

No

(No Data)

22507.16

No

(No Data)

No

(No Data)

Yes

No

(No Data)

Yes

1

No

(No Data)

No

(No Data)

Yes

24

Yes

24

No

(No Data)

No

(No Data)

Yes

24

Yes

24

No

(No Data)

No

(No Data)

Yes

24

Yes

24

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

1

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

(No Data)

No

No

(No Data)

Yes

1

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

Yes

24

No

(No Data)

Yes

24

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

No

(No Data)

©2019 Clayton Services LLC. All rights reserved. Ownership and use of this report is governed by the legal agreement between Clayton and the party for which it was prepared. Any use not expressly authorized by such agreement, including reliance on this report by anyone other than such party, is prohibited.

EX-99.2

Exhibit 99.2 - Schedule 4

Client Name:	HOF 2019-3
Client Project Name:	HOF 2019-3
Start - End Dates:	9/26/2016 - 6/5/2019
Deal Loan Count:	8
Rating Agency ATR QM Data Fields
Loans in Report:	8

Loan Number

Loan Level ATR/QM Status

Application Date Prior to 1/10/2014

TRID Indicator

Lender Application Date

Broker Application Date

GSE Eligible

QRM Flag

ATR/QM Total Points and Fees

Rate Lock Date

APR

Bwr 1 Employment Indicator

Bwr 2 Employment Indicator

Bwr 1 Foreign National Indicator

Bwr 2 Foreign National Indicator

Residual Income Analysis in File

ATR/QM Residual Income

3113002866

Non-QM: Lender documented all ATR UW factors

No

Yes

XXXXXX

XXXXXX

No

No

10078

XXXXXX

5.5365

Employed

Unemployed

U.S. Citizen

U.S. Citizen

No

0

4461205702

Non-QM: Lender documented all ATR UW factors

No

Yes

XXXXXX

XXXXXX

No

No

5675

XXXXXX

6.5495

Employed

Employed

U.S. Citizen

U.S. Citizen

No

0

4461206452

ATR/QM: Not Applicable

No

Yes

XXXXXX

XXXXXX

No

No

3121

XXXXXX

7.1164

Employed

Employed

U.S. Citizen

U.S. Citizen

(No Data)

0

4461212005

ATR/QM: Not Applicable

No

Yes

XXXXXX

XXXXXX

No

No

0

XXXXXX

6.4504

Employed

(No Data)

Non-Resident Alien

(No Data)

(No Data)

0

4461213367

Non-QM: Lender documented all ATR UW factors

No

Yes

XXXXXX

XXXXXX

No

No

5519.1

XXXXXX

7.4056

Employed

Unemployed

U.S. Citizen

U.S. Citizen

Yes

9481.12

4461215818

ATR/QM: Exempt

No

Yes

XXXXXX

XXXXXX

No

No

12225

XXXXXX

6.9094

Employed

(No Data)

U.S. Citizen

(No Data)

Yes

14356.93

4461217848

Non-QM: Lender documented all ATR UW factors

No

Yes

XXXXXX

XXXXXX

No

No

19877.5

XXXXXX

6.2023

Employed

(No Data)

U.S. Citizen

(No Data)

Yes

26758.51

5501799141

QM: Safe Harbor

No

Yes

XXXXXX

XXXXXX

No

Yes

14395

XXXXXX

4.9202

Employed

Employed

U.S. Citizen

U.S. Citizen

No

0

EX-99.2

Exhibit 99.2 - Schedule 5

Client Name:	HOF 2019-3
Client Project Name:	HOF 2019-3
Start - End Dates:	9/26/2016 - 6/5/2019
Deal Loan Count:	8
Valuations Summary

Loans in Report:		8			Origination Values					Automated Valuation Model				Desk Review				Second Desk Review				Field Review				Second Field Review				1004 SFR (Mar 05)				2055 Ext Only (Mar 05)				BPO (Broker Price Opinion)				Other					AUS Information
Loan Number	Seller Loan Number	Original Balance	Sales Price	Value for LTV	Appraised Date	Appraised Value	Review Date	Review Value	Review Type	Report Date	Value	Variance Amount	Variance (%)	Report Date	Value	Variance Amount	Variance (%)	Report Date	Value	Variance Amount	Variance (%)	Report Date	Value	Variance Amount	Variance (%)	Report Date	Value	Variance Amount	Variance (%)	Report Date	Value	Variance Amount	Variance (%)	Report Date	Report Value	Variance Amount	Variance (%)	Report Date	Value	Variance Amount	Variance (%)	Other - Valuation Type	Report Date	Value	Variance Amount	Variance (%)	CU Score
3113002866	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX		$0.00			$0.00	$0.00	0.00%	XXXXXX	XXXXXX	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	0	0.00%		$0.00	$0.00	0.00%			$0.00	$0.00	0.00%	(No Data)
4461205702	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX		$0.00			$0.00	$0.00	0.00%	XXXXXX	XXXXXX	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	0	0.00%		$0.00	$0.00	0.00%			$0.00	$0.00	0.00%	(No Data)
4461206452	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX		$0.00			$0.00	$0.00	0.00%	XXXXXX	XXXXXX	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	0	0.00%		$0.00	$0.00	0.00%			$0.00	$0.00	0.00%	(No Data)
4461212005	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX		$0.00			$0.00	$0.00	0.00%	XXXXXX	XXXXXX	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	0	0.00%		$0.00	$0.00	0.00%			$0.00	$0.00	0.00%	(No Data)
4461213367	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX		$0.00			$0.00	$0.00	0.00%	XXXXXX	XXXXXX	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	0	0.00%		$0.00	$0.00	0.00%			$0.00	$0.00	0.00%	(No Data)
4461215818	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	Desk		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	0	0.00%		$0.00	$0.00	0.00%			$0.00	$0.00	0.00%	(No Data)
4461217848	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	Desk		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	0	0.00%		$0.00	$0.00	0.00%			$0.00	$0.00	0.00%	(No Data)
5501799141	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX	XXXXXX		$0.00			$0.00	$0.00	0.00%	XXXXXX	XXXXXX	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	$0.00	0.00%		$0.00	0	0.00%		$0.00	$0.00	0.00%			$0.00	$0.00	0.00%	(No Data)

EX-99.3

Exhibit 99.3

 

EXECUTIVE SUMMARY

DESCRIPTION OF SERVICES

(1) Type of assets that were reviewed.

AMC Diligence, LLC (“AMC”) performed certain due diligence services (the “Review”) described below on four hundred seventy-six (476) mortgage loans acquired by Neuberger Berman Investment Advisors LLC (the “Client”) via Reliance Letters and six (6) mortgage loans reviewed directly for the Client. The Review was conducted from March 2019 through September 2019 on loans with origination dates from November 2017 through September 2019 via files imaged and provided by the Client or its designee for review.

(2) Sample size of the assets reviewed.

During the course of the securitization evaluation process, the Client may have removed loans that were reviewed by AMC from the securitization for paid-in-full mortgage loans or other items that were not disclosed to AMC. The final population of the Review covered four hundred eighty-two (482) mortgage loans totaling an aggregate original principal balance of approximately $387.973 million. To AMC’s knowledge, the Review covered 100% of the securitization loan population.

(3) Determination of the sample size and computation.

The Review was conducted consistent with the criteria, as may be relevant for this securitization, for the NRSRO(s) identified in Item 3 of the ABS Due Diligence-15E.

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

AMC compared data fields on the bid tape provided by the Client to the data found in the loan file as captured during the Review. The data integrity review was completed versus tapes as provided at the time of initial diligence or subsequently updated. As the securitization population includes loans from different periods of time and from differing transactions, not all data elements were provided to AMC on every loan within the securitization population. This comparison, when data was available, included the following data fields:

# of Borrowers	Doc Type	Original Loan Amount
# of Units	First Payment Date	Original LTV
Amortization Term	Index Type	Original P&I
Amortization Type	Interest Only	Original Term
Appraisal Date	Interest Only Period	Origination Channel
Appraised Value	Interest Rate Life Max	Origination Company Name
Balloon Flag	Interest Rate Life Min	Other Financing - Lien Position 2 - Original Loan Amount
Borrower First Name	Investor: Qualifying Total Debt Ratio	Property Type
Borrower Last Name	Lien Position	Purpose
Borrower Qualifying FICO	Lookback Period	Refi Purpose
Borrower Self-Employed?	LTV Valuation Value	Representative FICO
Borrower SSN	Margin	Rounding Factor
City	Maturity Date	Secondary Appraisal Date
Coborrower First Name	MERS Min Number	Secondary Appraised Value
Coborrower Last Name	Note Date	State
Coborrower Self-Employed?	Occupancy	Street
Coborrower SSN	Original CLTV	Total Cash-out
Contract Sales Price	Original Interest Rate	Zip

Additional information about the data integrity review is included in Item 5 below.

1| Page

MORTGAGE REVIEW (482 Loans)

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

AMC reviewed asset origination to determine conformity to the stated underwriting or credit extension guidelines, standards, criteria or other requirements, including, as applicable, the Ability to Repay and Qualified Mortgage requirements described below, that were provided to AMC. When applicable, a review of the mortgage loan file to the Automated Underwriting System output within the mortgage loan file was also performed.

Credit Application: For the Credit Application, AMC verified that the application: (i) was signed by all listed borrowers, (ii) was substantially filled out, (iii) contained all known borrower-owned properties on the Real Estate Owned section 2, and (iv) included the borrower’s employment history.

Credit Report: AMC’s review included confirming that a credit report, that met guideline requirements, was present for each borrower and that such borrower’s credit profile adhered to the guidelines. In order to make this determination, AMC: (i) captured the monthly consumer debt payments for use in relevant calculations, (ii) noted and researched the Real Estate Owned and fraud alerts, (iii) gathered liabilities listed on the credit report to be included in the debt to income ratio as appropriate, and (iv) gathered data required for the ASF tape submission including (a) the most recent FICO (scores from Equifax, Experian, and Transunion if available), (b) the most recent FICO date, (c) the longest trade line, (d) the maximum trade line, (e) the number of trade lines, and (f) the credit usage ratio.

Employment and Income: AMC determined whether applicable supporting employment and income documentation required by the guidelines, and as applicable Appendix Q or ATR, was present in the mortgage loan file and where possible, wasn’t fraudulent. This documentation was used to verify whether the income used to qualify the mortgage loan was calculated in accordance with the guidelines and may have included items such as: (i) verbal or written verification of employment, (ii) pay stubs, (iii) W-2 forms, (iv) tax returns, (v) financial statements, (vi) IRS tax transcripts, and (vii) Bank Statements.

Asset Review: AMC assessed whether the asset documentation required by the guidelines, and as applicable, Appendix Q or ATR, was present in the mortgage loan file. Utilizing this documentation, AMC completed a review of the reserve calculation and any large deposits. Documentation verifying assets for down payment, closing costs, prepaid items and reserves may have included: (i) verification-of-deposit (“VOD(s)”), (ii) depository account statements, (iii) stock or security account statements, (iv) gift funds, (v) escrow or earnest money deposits, and (vi) settlement statements or other evidence of conveyance and transfer of funds (if a sale of assets was involved).

Hazard/Flood Insurance/Taxes: A review of the insurance present on the mortgage loan was also performed by AMC. During the course of this review, AMC (i) verified that the hazard insurance met the minimum required amount of coverage in the guidelines, (ii) confirmed that the mortgage clause listed the lender’s name and “its successors and assigns,”, (iii) confirmed that the premium amount on both the hazard and flood insurance matched what was used in the DTI calculations, (iv) reviewed the tax certificate to verify and compare monthly escrows used to calculate DTI matched and that taxes were current, (v) confirmed that the flood certification was for the correct borrower, property, lender and mortgage loan number and was a “Life of Loan” certification, and (vi) completed other property specific items including (a) for condominium properties, confirming that the blanket policy met the minimum amount of coverage in the guidelines and (b) for properties in a flood zone per the flood certification, confirming that flood insurance met guideline requirements and met the minimum required amount of coverage in the guidelines.

Occupancy Review: AMC confirmed the property occupancy is consistent with the mortgage loan approval and borrowers’ application disclosure based solely on information contained in the mortgage loan file and any fraud report obtained in connection with the mortgage loan.

Guideline Review: During the course of the review, AMC confirmed the mortgage loan was originated in accordance with required guidelines by reviewing conformity of mortgage loan, transaction type, and borrower characteristics to stated guidelines. Mortgage characteristics examined included (i) DTI of the borrower, (ii) the LTV/TLTV/HTLTV, (iii) the credit score for each borrower, (iv) asset reserves of the borrower, (v) property type, (vi) property usage, and (vii) other property specific items including (a) for condominium or cooperative properties, assessing whether the condominium or cooperative project adheres to required guidelines.

2| Page

Fraud Review: AMC reviewed fraud report results in each mortgage loan file, to the extent present, in conjunction with source documents found in the mortgage loan file to assess the likelihood of any misrepresentations associated with the origination of the mortgage loan. If the mortgage loan file did not contain a fraud report and the counterparty did not produce one, AMC conditioned the mortgage loan for the missing fraud report product.

If a report was present, AMC reviewed the report for (i) any name variations for the borrowers, (ii) any social security number variations for the borrowers, (iii) any potential occupancy issues based on the borrower’s address history, (iv) any noted employment issues, and (v) any additional consumers associated with the borrower’s profile. If any findings were noted, AMC confirmed that such findings and/or variations were addressed by the originator in the origination of the asset or that such red flag issues were fully addressed via mortgage loan documentation provided.

Additional Review of Mortgage Loan File: AMC also reviewed the closing documents to ensure that the mortgage loan file information is complete, accurate, and contains consistent documentation. Included in the portion of the review are items such as reviewing for (i) evidence of primary mortgage insurance, (ii) if the property is located in an area that was listed as a FEMA disaster zone post origination, (iii) the presence of loan modification documents, and (iv) general conformity to Fannie Mae or Freddie Mac approved formats at the time of origination.

If standard GSE forms were not used for the mortgage loan, AMC sought to confirm the existence of: (i) a “due on sale” clause, (ii) mortgagor’s requirement to maintain adequate insurance at the mortgagor’s own expense, and (iii) the holder’s right to foreclose and to confirm that any homestead exemption has been waived as required by applicable law within the forms utilized.

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

AMC’s review included a review of the valuation materials utilized during the origination of the loan and in confirming the value of the underlying property. AMC’s review included verifying the appraisal report was (i) on the appropriate GSE form, (ii) materially complete, (iii) in conformity with the guideline requirements for the property type in question, (iv) completed by an appraiser that was actively licensed to perform the valuation, (v) completed such that the named client on the appraisal report is the lender or a related entity that is permitted to engage the lender per Title XI of FIRREA, (vi) made and signed prior to the final approval of the mortgage loan application, (vii) completed and dated within the guideline requirements, (vii) made on an “as is” basis or provides satisfactory evidence of completion of all material conditions including all inspections, licenses, and certificates (including certificates of occupancy) to be made or issued with respect to all occupied portions of the mortgaged property and with respect to the use and occupancy of the same, have been made or obtained from the appropriate authorities.

With regard to the use of comparable properties, AMC’s review (i) captured the relative comparable data (gross and net adjustments, sale dates and distance from subject property) and ensured that such comparable properties are within standard appraisal guidelines; (ii) confirmed the property value and square footage of the subject property was bracketed by comparable properties, (iii) verified that comparable properties used are similar in size, style, and location to the subject, and (iv) checked for the reasonableness of adjustments when reconciling value between the subject property and comparable properties.

Other aspects of AMC’s review included (i) verifying that the address matched the mortgage note, (ii) verifying that the appraisal  and the policies and procedures with regard to appraisal, including the appropriate level of review, when originating the mortgage loan, were followed, (iii) noting whether the property zip code was declared a FEMA disaster area after the valuation date and notifying the Client of same (iv) confirming the appraisal report does not include any apparent environmental problems, (v) confirming the appraisal notes the current use of the property is legal or legal non-conforming (grandfathered), (vi) reviewing pictures to ensure (a) that the property is in average or better condition and any repairs are noted where required and (b) that the subject property is the one for which the valuation was ordered and that there are no negative external factors; and (vii) confirming that the value product that was used as part of the origination decision was directly accessible to AMC or if it was not directly accessible that another valuation product that was directly accessible to AMC was ordered in accordance with the Client’s specific valuation waterfall process. If more than one valuation was provided, AMC confirmed consistency among the valuation products and if there were discrepancies that could not be resolved, AMC created an exception.

(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.

With regard to TILA-RESPA Integrated Disclosure (“TRID”) testing, AMC implemented the TRID scope of review referenced within the Regulatory Compliance section (III) based on (i) the RMBS 3.0 TRID Compliance Review Scope published by the Structured Finance Industry Group (the "SFIG Compliance Review Scope") and (ii) outside counsel’s interpretations of the published regulations as of the date of review of each mortgage loan. AMC worked with outside counsel and continues to obtain updated interpretations relative to the informal guidance provided by the Consumer Financial Protection Bureau (“CFPB”) which has caused alterations in the review scope and severity of TRID related exceptions, including applicable cures. (This will continue as necessary as additional guidance becomes available, as well as any future rulemaking.) While AMC continues to make a good faith effort to identify material TRID exceptions and apply the appropriate grading, the implementation of new regulations (including TRID) that impact residential mortgages carries certain interpretive risk and continues to evolve, impacting the review scope and exception severity. AMC has worked closely with the NRSROs and the Client to disclose, as mutually agreed upon by the parties, the relevant exceptions per AMC’s suggested review implementation as reviewed by outside counsel; however, no assurances can be provided and/or are given that AMC has included within its Review all areas that may represent risk to the securitization trust, or that areas of risk identified by AMC will result in the potential level of risk indicated by an Event Level or NRSRO grade. Please note that investment properties were excluded from TRID testing.

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

(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;

vi) any material disclosure violation on a rescindable mortgage 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, or those related to prepayment penalties on covered transactions; and

vii) with respect to applicable exception remediation measures, confirm that a letter of explanation, a refund if applicable, new corrected material disclosures and a new notice of right to cancel was provided.

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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

ii) compliance with the escrow account and appraisal requirements.

f) With respect to brokered mortgage loans, the Prohibitions and Restrictions related to Loan Originator Compensation and Steering (§1026.36):

i) review relevant documentation to determine if compensation to a Loan Originator was based on a term of the transaction;

ii) review relevant document to determine if there was dual compensation; and

iii) review the presence of the mortgage loan option disclosure and to determine if the Steering Safe Harbor provisions were satisfied.

(1) Note: Where available, AMC reviewed the relevant documents in the mortgage loan file and, as necessary, attempted to obtain the mortgage loan originator compensation agreement and/or governing policies and procedures of the mortgage loan originator. In the absence of the mortgage loan originator compensation agreement and/or governing policies and procedures, AMC’s review was limited to formal general statements of entity compliance provided by the mortgage loan originator, if any. These statements, for example, were in the form of a letter signed by the seller correspondent/mortgage loan originator or representations in the mortgage loan purchase agreement between the Client and seller correspondent;

g) Homeownership counseling (§1026.36):

i) determine if the creditor obtained proof of homeownership counseling in connection with a mortgage loan to a first time homebuyer that contains a negative amortization feature.

h) Mandatory Arbitration Clauses (§1026.36):

i) determine if the terms of the mortgage loan require arbitration or any other non-judicial procedure to resolve any controversy or settle any claims arising out of the transaction.

i) Prohibition on Financing Credit Insurance (§1026.36):

i) determine if the creditor financed, directly or indirectly, any premiums or fees for credit insurance.

j) Nationwide Mortgage Licensing System (NMLS) & Registry ID on Loan Documents (§1026.36):

i) review for presence of mortgage loan originator organization and individual mortgage loan originator name and NMLSR ID, as applicable, on the credit application, note or mortgage loan contract, security instrument, Loan Estimate and Closing Disclosure; and

ii) verify the data against the NMLSR database, as available.

(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 mortgage loan terms and/or fees on any revised GFEs over the applicable tolerance(s); and

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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 mortgage 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 mortgage 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 mortgage 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 mortgage 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 mortgage loan file or that the mortgage 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 mortgage 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 mortgage loan file and proper timing;

ix) confirm that the creditor provided the borrower a list of homeownership counselling organizations within three (3) business days of application; and

x) confirm that the list of homeownership counselling organizations was obtained no earlier than 30 days prior to when the list was provided to the mortgage loan applicant.

(III) Sections 1098 and 1100A of Dodd-Frank amending TILA and RESPA, as implemented by Regulation Z, 12 C.F.R. Part 1026, as set forth below (applicable only for mortgage loans with application dates on or after October 3, 2015):

a) Loan Estimate (LE) (§§1026.19 and 37):

i) confirm the presence of LE for applications on or after October 3, 2015;

ii) confirm the initial LE date indicates it was delivered or placed in the mail within three (3) business days of application;

iii) confirm that certain sections of each LE determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the LE;

iv) confirm the initial LE was delivered or placed in the mail not later than seven (7) business days prior to consummation of the transaction, or such period was waived due to a bona fide financial emergency;

v) confirm that any written estimate of terms or costs provided prior to receipt of a LE contained the required disclosures;

vi) confirm that each revised LE is accompanied by valid written documentation explaining the reason for re-disclosure to allow for fee increases based on a valid change of circumstance and was timely provided within 3 business days of issuance;

vii) confirm the presence and timely provision of a settlement service provider list (when consumer is given the opportunity to shop for services);

viii) confirm borrower received LE not later than four (4) business days prior to consummation; and

ix) confirm LE was not provided to the borrower on or after the date of the CD.

b) Closing Disclosure (CD) (§§1026.19 and 38):

i) confirm the presence of CD for applications on or after October 3, 2015;

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ii) confirm the borrower received CD at least three (3) business days prior to consummation, or that such period was waived due to a bona fide financial emergency;

iii) confirm that certain sections of each CD determined to carry assignee liability were accurately completed and that information was reflected in the appropriate locations, which, in certain instances, was based solely on the information disclosed on the CD;

iv) confirm that a revised CD was received in a timely manner if the initial or any revised CD became inaccurate;

v) identify tolerance violations based on the charges disclosed on the initial and interim LE’s, initial CD, and reflected on the final CD;

vi) with respect to tolerance violations based on the disclosed charges on the LE and CD, confirm that the creditor cured the violations no later than 60 days after consummation, or within 60 days of discovery; and

vii) with respect to applicable exception remediation measures for numerical exceptions, confirm that a letter of explanation, as well as a refund as applicable, was delivered or placed in the mail no later than 60 days after discovery of the exception establishing the need for a revised CD or with respect to exception remediation measures for non-numerical exceptions, that a corrected CD was delivered or placed in the mail no later than 60 days after consummation. (In an attempt to establish a best practices approach to pre-securitization due diligence, as it applies to TILA RESPA Integrated Disclosure testing, the Structured Finance Industry Group (“SFIG”) has a working group that consists of industry participants including third party review providers and law firms who agreed to a standardized approach to remediation considerations. This approach is intended to be based on a reasoned legal analysis that expressly assumes that courts will interpret TRID in accordance with the principals of liability set forth in the letter to the MBA from Richard Cordray, the Director of the CFPB. No assurances can be provided that the courts in question will interpret TRID in accordance with the SFIG Compliance Review Scope.)

c) Your Home Loan Toolkit (§1026.19):

i) confirm the presence of Your Home Loan Toolkit in the mortgage loan file or that the mortgage loan file contains documentary evidence that the disclosure was provided to the borrower; and

ii) confirm Your Home Loan Toolkit was delivered or placed in the mail not later than three (3) business days after receipt of application.

(IV) Sections 1411 and 1412 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) amending TILA, as implemented by Regulation Z, 12 C.F.R. 1026.43, as set forth below:

a) The general Ability to Repay (ATR) underwriting standards (12 C.F.R. 1026.43(c));

b) Refinancing of non-standard mortgages (12 C.F.R. 1026.43(d));

c) Qualified Mortgages (QM) (12 C.F.R. 1026.43(e) (including qualified mortgages as separately defined by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.), and the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.); and

d) Balloon-payment qualified mortgages made by certain creditors (12 C.F.R. 1026.43(f)).

AMC reviews applicable mortgage loans for compliance with the ATR and QM rule requirements based upon each mortgage loan’s originator designation (Safe Harbor QM, Higher-priced QM, Temporary SHQM, Temporary HPQM, Non-QM, Exempt from ATR). AMC determines the mortgage loan’s status under the ATR or QM rule requirements and assigns a due diligence mortgage loan designation. Generally, AMC notes as a material exception if the due diligence findings do not confirm the originator’s mortgage loan designation. Additionally, AMC notes if an originator mortgage loan designation was not provided.

Qualified Mortgage

With respect to QM (Safe Harbor and Higher-priced) designated mortgage loans, AMC reviews the mortgage loan to determine whether, based on available information in the mortgage loan file: (i) the mortgage loan contains risky mortgage loan features and terms (e.g. an interest only feature or negative amortization), (ii) the “points and fees” exceed the applicable QM threshold, (iii) the monthly payment was calculated appropriately, (iv) the creditor considered and verified income or assets at or before consummation, (v) the creditor appropriately considered debt obligations, alimony and child support, and (vi) at the time of consummation, if the debt-to-income ratio exceeds 43% (calculated in accordance with Appendix Q to Regulation Z). This portion of the Review includes a recalculation of all income and liabilities with attention to the appropriate documentation of each source.

If a mortgage loan was designated as QM and identified as eligible for guarantee, purchase, or insurance by an applicable agency as permitted under the QM final rule, AMC reviews the mortgage loan to determine whether, based on available

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information in the mortgage loan file, if the mortgage loan satisfied (i), (ii) and (iii) in the preceding paragraph. In addition, AMC reviews the Automated Underwriting System output within the file to confirm agency eligibility.

For each QM designated mortgage loan that satisfied the applicable requirements enumerated above, AMC then determines whether the mortgage loan is a Safe Harbor QM or Higher Priced QM by comparing the mortgage loan’s actual annual percentage rate, as recalculated, to the applicable average prime offer rate plus a certain applicable percentage. The Review also includes determining, as applicable, whether a mortgage loan is a qualified mortgage as defined by the Department of Housing and Urban Development (24 C.F.R. 201 and 203 et seq.), and the Department of Veterans Affairs (38 C.F.R. Part 36 et seq.).

For each QM designated mortgage loan that does not satisfy the applicable requirements enumerated above, AMC then determines whether the mortgage loan complies with the ATR rule consideration and verification requirements and provides a due diligence designation of Non-QM compliant or non-compliant.

General Ability to Repay

AMC reviews the mortgage loan to determine whether, based on available information in the mortgage loan file, the creditor considered, as applicable, the following eight underwriting factors, and verified such information using reasonably reliable third-party records, at or before consummation: (i) the consumer's current or reasonably expected income or assets, (ii) if the creditor relied on income from the consumer's employment in determining repayment ability (the consumer's current employment status); (iii) the consumer's monthly payment; (iv) the consumer's monthly payment on any simultaneous loan that the creditor knows or has reason to know will be made; (v) the consumer's monthly payment for mortgage-related obligations; (vi) the consumer's current debt obligations, alimony, and child support; (vii) the consumer's monthly debt-to-income ratio or residual income; and (viii) the consumer's credit history. This portion of the Review also focuses on full recalculation of income and debts, as well as the documentation provided to support each item used in originator’s determination of the ability to repay.

AMC reviews mortgage loans to determine their conformity with the ATR/QM factors above, and is not rendering an independent assessment or opinion, warranting or representing that a mortgage loan will be deemed to conform to Safe Harbor, Rebuttable Presumption, ATR or other status based on any additional or revised factors that may be considered by legislative, regulatory, administrative or judicial authorities (“Authorities”). AMC does not represent or warrant that the factors for which it is reviewing the mortgage loans constitute all of the factors and/or criteria that Authorities may consider in determining the status of a mortgage loan. AMC’s review is based on information contained in the mortgage loan file at the time it is provided to AMC to review, and only reflects information as of that point in time.

(V) The Equal Credit Opportunity Act, as implemented by Regulation B, 12 C.F.R. Part 1002, as set forth below:

a) Providing Appraisals and Other Valuations (12 C.F.R. 1002.14):

i) timing and content of the right to receive copy of appraisal disclosure;

ii) charging of a fee for a copy of the appraisal or other written valuation;

iii) timing of creditor providing a copy of each appraisal or other written valuation; and

iv) with respect to a borrower that has waived the three (3) business day disclosure requirement, confirm that (a) the borrower has signed the waiver or other acknowledgment at least three (3) business days prior to consummation; and (b) that the lender has provided copies of appraisals and other written valuations at or prior to consummation.

(VI) Fannie Mae points and fees limitations and HOEPA restrictions as addressed in Fannie Mae Announcement 04-06, as amended by Lender Letters LL-2013-05 and LL-2013-06 and Selling Guide Announcement SEL-2013-06;

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

(VIII) The disclosure requirements and prohibitions of state, county and municipal laws and ordinances with respect to “high-cost” mortgage loans, “covered” mortgage loans, “higher-priced” mortgage loans, “home” mortgage loans or any other similarly designated mortgage 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;

(IX) Federal and state specific late charge and prepayment penalty provisions.

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(X) Recording Review

AMC noted the presence of recorded documents, when available. However, the majority of mortgage loans in the review population were new production and have only been closed for days or weeks at the time AMC reviewed the mortgage loans and thus have not yet been recorded. AMC verified that documents in the mortgage loan file (most typically closing instructions) included lender instructions for recording, and as applicable, the date the documents were sent for recording, and/or the date that the documents will be recorded.

As part of the portion of the Review described in this section, AMC will analyze and capture data from the source documents identified in the Document Review below, as applicable.

(XI) FIRREA Review

AMC confirmed that the appraiser and the appraisal made by such appraiser both satisfied the requirements of Title XI of FIRREA. Specifically, AMC reviewed the appraisal for conformity to industry standards, including ensuring the appraisal was complete, that the comparable properties and adjustments were reasonable and that pictures were provided and were accurate. In addition, AMC accessed the ASC database to verify that the appraiser, and if applicable the appraiser’s supervisor, were licensed and in good standing at the time the appraisal was completed. 

(XII) Document Review

AMC reviewed each mortgage loan file and verified if the following documents, if applicable, were included in the file and if the data on these documents was consistent (where applicable):

• Initial application (1003);
• Underwriting summary / loan approval (1008);
• Credit report;
• Income and employment documentation;
• 4506T;
• Asset documentation;
• Sales contract;
• Hazard and/or flood insurance policies;
• Copy of note for any junior liens;
• Appraisal;
• Title/Preliminary Title;
• Final 1003;
• Changed circumstance documentation;
• Right of Rescission Disclosure;
• Mortgage/Deed of Trust;
• Note;
• Mortgage Insurance;
• Tangible Net Benefit Disclosure;
• Subordination Agreement;
• FACTA disclosures;
• Notice of Special Flood Hazards;
• Initial and final GFE’s;
• HUD from sale of previous residence;
• Final HUD-1;
• Initial TIL;
• Final TIL;
• Loan Estimates;
• Closing Disclosures; and
• Certain other disclosures related to the enumerated tests set forth herein.

SUMMARY OF FINDINGS & CONCLUSIONS

The NRSRO criteria referenced for this report and utilized for grading descriptions is based upon the requirements of the NRSROs listed in the Form ABS Due Diligence-15E.

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COMPLIANCE RESULTS SUMMARY

Within the securitization population, 17.63% of the loans by number possessed an “A” compliance grade and 97.51% of the loans by number possessed a “B” credit grade or higher. Twelve (12) loans received a compliance grade of “C”.

NRSRO Grade	# Loans	% of Loans
A	85	17.63%
B	385	79.88%
C	12	2.49%
Total	482	100.00%

CREDIT RESULTS SUMMARY

Within the securitization population, 59.96% of the loans by number possessed an “A” credit grade and 100.00% of the loans by number possessed a “B” credit grade or higher.

NRSRO Grade	# Loans	% of Loans
A	289	59.96%
B	193	40.04%
C	0	0.00%
Total	482	100.00%

PROPERTY/VALUATION RESULTS SUMMARY

Within the securitization population, 99.79% of the loans by number possessed an “A” property grade and 100% of the loans by number possessed a “B” property grade or higher.

NRSRO Grade	# Loans	% of Loans
A	481	99.79%
B	1	0.21%
C	0	0.00%
Total	482	100.00%

OVERALL RESULTS SUMMARY

After considering the grading implications of the Compliance, Credit, and Property/Valuation sections above, 97.51% of the loans by number in the pool possessed a NRSRO grade of “A”, or “B”.

NRSRO Grade	# Loans	% of Loans
A	60	12.45%
B	410	85.06%
C	12	2.49%
Total	482	100.00%

*Some tables may not add to 100% due to rounding.

EXCEPTION CATEGORY SUMMARY

The table below summarizes the individual exceptions which carried an associated “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception. 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”).

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Exception Type	Exception Level Grade	Exception Category	Total
Compliance	C	TRID Defect	21
		Federal HPML	3
		Total Compliance Grade (C) Exceptions:	24
	B	TRID	506
		Missing Disclosure	158
		TRID Defect	133
		ECOA	66
		State HPML	52
		ATR/QM Defect	49
		RESPA	39
		ATR/QM	34
		Missing Non-Required Data	15
		Compliance	10
		Federal HPML	9
		Misc. State Level	5
		Missing, Incorrect, or Incomplete Final or Initial 1003	4
		GSE	4
		FACTA	3
		TILA	3
		TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form	2
		Flood	2
		State Defect	1
		Missing Application Date	1
		State Higher Priced Mortgage Loan and related exceptions	1
		Total Compliance Grade (B) Exceptions:	1,097
Total Compliance Exceptions:			1,121
Credit	B	Credit	207
		Guideline	25
		Borrower and Mortgage Eligibility	20
		Income / Employment	17
		Asset	10
		Insurance	5
		Loan Package Documentation	5
		Income	3
		Property - Appraisal	2
		Data Verification	1
		Total Credit Grade (B) Exceptions:	295
Total Credit Exceptions:			295
Property	B	Property - Appraisal	1
		Total Property Grade (B) Exceptions:	1
Total Property Exceptions:			1
Grand Total:			1,417

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TAPE INTEGRITY REVIEW RESULTS SUMMARY

Of the four hundred eighty-two (482) loans reviewed, there were eighty-three (83) different tape discrepancies across twenty-one (21) data fields (some loans had more than one data delta). Not all data fields were provided on all loans within the securitization population.

Field Label	Loans With Discrepancy	Total Times Compared	% Variance	# Of Loans
Doc Type	14	41	34.15%	482
Investor: Qualifying Total Debt Ratio	8	23	34.78%	482
Property Type	8	41	19.51%	482
Original Term	7	41	17.07%	482
Representative FICO	7	40	17.50%	482
Appraisal Date	6	16	37.50%	482
Secondary Appraisal Date	5	16	31.25%	482
Margin	4	19	21.05%	482
MERS Min Number	4	16	25.00%	482
Refi Purpose	4	10	40.00%	482
Origination Company Name	3	16	18.75%	482
Borrower Self-Employed?	2	16	12.50%	482
Coborrower Self-Employed?	2	16	12.50%	482
Contract Sales Price	2	37	5.41%	482
Amortization Term	1	17	5.88%	482
Amortization Type	1	7	14.29%	482
Borrower First Name	1	22	4.55%	482
LTV Valuation Value	1	40	2.50%	482
Occupancy	1	49	2.04%	482
Secondary Appraised Value	1	3	33.33%	482
Street	1	30	3.33%	482
# of Borrowers	0	1	0.00%	482
# of Units	0	40	0.00%	482
Appraised Value	0	1	0.00%	482
Balloon Flag	0	16	0.00%	482
Borrower Last Name	0	32	0.00%	482
Borrower Qualifying FICO	0	1	0.00%	482
Borrower SSN	0	16	0.00%	482
City	0	49	0.00%	482
Coborrower First Name	0	6	0.00%	482
Coborrower Last Name	0	6	0.00%	482
Coborrower SSN	0	6	0.00%	482
First Payment Date	0	17	0.00%	482
Index Type	0	1	0.00%	482
Interest Only	0	16	0.00%	482

12| Page

Interest Only Period	0	2	0.00%	482
Interest Rate Life Max	0	1	0.00%	482
Interest Rate Life Min	0	1	0.00%	482
Lien Position	0	23	0.00%	482
Lookback Period	0	1	0.00%	482
Maturity Date	0	16	0.00%	482
Note Date	0	1	0.00%	482
Original CLTV	0	23	0.00%	482
Original Interest Rate	0	41	0.00%	482
Original Loan Amount	0	49	0.00%	482
Original LTV	0	41	0.00%	482
Original P&I	0	16	0.00%	482
Origination Channel	0	1	0.00%	482
Other Financing - Lien Position 2 - Original Loan Amount	0	1	0.00%	482
Purpose	0	49	0.00%	482
Rounding Factor	0	1	0.00%	482
State	0	49	0.00%	482
Total Cash-out	0	1	0.00%	482
Zip	0	31	0.00%	482
Total	83	1,072	7.74%	482

ADDITIONAL MORTGAGE LOAN POPULATION SUMMARY*

Amortization Type	Loan Count	% of Loans	Original Balance	% of Balance
Adjustable	379	78.63%	$341,980,543.00	88.15%
Fixed	103	21.37%	$45,993,231.00	11.85%
Total	482	100.00%	$387,973,774.00	100.00%
Lien Position	Loan Count	% of Loans	Original Balance	% of Balance
1	482	100.00%	$387,973,774.00	100.00%
Total	482	100.00%	$387,973,774.00	100.00%
Loan Purpose	Loan Count	% of Loans	Original Balance	% of Balance
Other-than-first-time Home Purchase	216	44.81%	$188,232,481.00	48.52%
First Time Home Purchase	131	27.18%	$71,569,603.00	18.45%
Cash Out: Other/Multi-purpose/Unknown Purpose	82	17.01%	$80,608,774.00	20.78%
Rate/Term Refinance - Borrower Initiated	29	6.02%	$30,449,753.00	7.85%
Cash Out: Debt Consolidation	17	3.53%	$9,849,300.00	2.54%
Cash Out: Home Improvement/Renovation	7	1.45%	$7,263,863.00	1.87%
Total	482	100.00%	$387,973,774.00	100.00%

13| Page

Original Term	Loan Count	% of Loans	Original Balance	% of Balance
241-360 Months	396	82.16%	$280,990,270.00	72.43%
361+ Months	86	17.84%	$106,983,504.00	27.57%
Total	482	100.00%	$387,973,774.00	100.00%
Property Type	Loan Count	% of Loans	Original Balance	% of Balance
Single Family Detached	276	57.26%	$228,486,079.00	58.89%
PUD	118	24.48%	$91,305,995.00	23.53%
Condo, Low Rise	47	9.75%	$33,483,689.00	8.63%
Condo, High Rise	14	2.90%	$16,535,730.00	4.26%
2 Family	10	2.07%	$7,867,513.00	2.03%
1 Family Attached	6	1.24%	$5,683,280.00	1.46%
Other	6	1.24%	$1,852,780.00	0.48%
3 Family	5	1.04%	$2,758,708.00	0.71%
Total	482	100.00%	$387,973,774.00	100.00%
Occupancy	Loan Count	% of Loans	Original Balance	% of Balance
Primary	424	87.97%	$329,691,271.00	84.98%
Investment	36	7.47%	$33,634,354.00	8.67%
Second Home	22	4.56%	$24,648,149.00	6.35%
Total	482	100.00%	$387,973,774.00	100.00%
Originator Loan Designation	Loan Count	% of Loans	Original Balance	% of Balance
Non QM	445	92.32%	$353,339,420.00	91.07%
N/A	36	7.47%	$33,634,354.00	8.67%
Safe Harbor QM	1	0.21%	$1,000,000.00	0.26%
Total	482	100.00%	$387,973,774.00	100.00%
TPR Loan Designation	Loan Count	% of Loans	Original Balance	% of Balance
Non QM	444	92.12%	$347,496,920.00	89.57%
N/A	36	7.47%	$33,634,354.00	8.67%
Safe Harbor QM	1	0.21%	$1,000,000.00	0.26%
ATR Risk	1	0.21%	$5,842,500.00	1.51%
Total	482	100.00%	$387,973,774.00	100.00%
Review Type	Loan Count	% of Loans	Original Balance	% of Balance
Credit/Compliance - TRID	482	100.00%	$387,973,774.00	100.00%
Total	482	100.00%	$387,973,774.00	100.00%

*Some tables may not add to 100% due to rounding.

14| Page

EX-99.3

Exhibit 99.3 - Schedule 1

Rating Agency Grades

Run Date - 10/31/2019 1:16:40 PM

LOAN INFORMATION

INITIAL CREDIT LOAN GRADES

INITIAL COMPLIANCE LOAN GRADES

INITIAL PROPERTY LOAN GRADES

INITIAL OVERALL LOAN GRADES

FINAL CREDIT LOAN GRADES

FINAL COMPLIANCE LOAN GRADES

FINAL PROPERTY LOAN GRADES

FINAL OVERALL LOAN GRADES

AMC Loan ID

Customer Loan ID

Seller Loan ID

Deal Number

Original Loan Amount

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

DBRS

Fitch

Kroll

Moody's

S&P

Morningstar

203612014

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XXXXXX

XXXXXX

XXXXXX

C

C

C

C

C

C

C

C

C

C

C

C

A

A

A

A

A

A

C

C

C

C

C

C

B

B

B

B

B

B

B

B

B

B

B

B

A

A

A

A

A

A

B

B

B

B

B

B

208488773

XXXXXX

XXXXXX

XXXXXX

XXXXXX

C

C

C

C

C

C

C

C

C

C

C

C

A

A

A

A

A

A

C

C

C

C

C

C

B

B

B

B

B

B

B

B

B

B

B

B

A

A

A

A

A

A

B

B

B

B

B

B

208488774

XXXXXX

XXXXXX

XXXXXX

XXXXXX

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

C

B

B

B

B

B

B

B

B

B

B

B

B

A

A

A

A

A

A

B

B

B

B

B

B

EX-99.3

Exhibit 99.3 - Schedule 2

 

Exception Grades

Run Date - 10/31/2019 1:16:41 PM

AMC Loan ID

Customer Loan ID

Seller Loan ID

Loan Exception ID

Exception ID

Exception Date

Exception Type

Exception Category

Exception Subcategory

Exception

Exception Detail

Exception Information

Compensating Factors

Applying Party

Follow-up Comments

Cleared Date

Cured Date

Waived Date

Exception Level Grade

Exception Level Rating

Note Date

Property State

Occupancy

Purpose

Exception Remediation

Overall Initial Loan Grade

Overall Final Loan Grade

Credit Initial Loan Grade

Credit Final Loan Grade

Compliance Initial Loan Grade

Compliance Final Loan Grade

Property Initial Loan Grade

Property Final Loan Grade

Originator QM ATR Status

TPR QM ATR Status

Is Curable

203612014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.61280% or Final Disclosure APR of 7.61600% is in excess of allowable threshold of APOR 4.10% + 1.5%, or 5.60000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2018-06-01): XXXXXX mortgage purXXXXXXs HPML compliant loans.

02/07/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

203612014

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

HOA Questionnaire verifies 23% of the units in the subject condo project are 60 or more days delinquent on HOA fees, which exceeds the maximum of 15% as required by SP - A5 Non-Warrantable Condo guidelines. Lender approved the exception.

Lender exception comment: Credit score is 654, 14 points > program requirement of 640. 24.29% DTI on this Bank Statement documentation loan < 50% guideline max - 25.71% below program guideline maximum. 15.68 months reserves > 3 months guideline minimum - borrower has verified reserves of $48,838.10. Borrower has employment stability for 15 years as a XXXXXX Lender exception comment: Long established condo, control of HOA to unit owners xxx. Investor concentration is low (10 units out of xxx) and no commercial space.

Reviewer Comment (2018-06-01): XXXXXX has elected to waive this requirement based on compensating factors.

02/07/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

203612014

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application.

XXXXXX Subprime Loan: Counseling Disclosure was provided to and signed by the borrower on XXXXXX, which is not at the time of application on [Redacted].

Reviewer Comment (2018-06-01): XXXXXX has elected to waive this exception.

02/08/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

203612014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on [Redacted] was electronically provided prior to borrower's consent to receive electronic disclosures. (Initial/XXXXXX) [Redacted]

Borrowers consented to electronic disclosures on XXXXXX however, Loan Estimate was electronically provided to the borrowers on XXXXXX.

Reviewer Comment (2018-06-01): XXXXXX has elected to waive this exception.

02/08/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

No

203612014

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

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

Credit Report: Original // Borrower: XXXXXX

Most recent Fraud Report dated [Redacted] reflects the following Red Flags: 1) The score indicates that this loan has a high probability of loss due to fraudulent misrepresentation. 2) Purchase transaction with multiple high risk factors. 3)  Borrower income consistent with historical patterns of risk. 4) The disclosed 1003 income is significantly higher than the neighborhood incomes of where the borrower has lived. 5) Difference between stated property value and automated property valuation output associated with high historical fraud rate. File is missing documentation to verify these red flags were addressed and cleared.

Reviewer Comment (2018-06-01): Red flags were addressed as income was addressed by verification of income utilizing 12 months bank statements and CPA letter. Appraisal was performed by third party and a CDA was performed to re-validate the appraised value.

02/08/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

203612014

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

The borrower is self-employed.  Guidelines require either a tax professional letter or regulatory agency verifying at least 2 years of self-employment along with either a phone listing and/or business address using directory assistance or internet search to be in file.

Borrower has been self-employed less than 2 years as required by [Redacted] Income per Bank Statements guidelines. Lender approved the exception.

Lender exception comment: Credit score is 654, 14 points > program requirement of 640. 24.29% DTI on this Bank Statement documentation loan < 50% guideline max - 25.71% below program guideline maximum. 15.68 months reserves > 3 months guideline minimum - borrower has verified reserves of $48,838.10. Borrower has employment stability for 15 years as a XXXXXX Lender exception comment: Long established condo, control of HOA to unit owners xxxx. Investor concentration is low (10 units out of xxx) and no commercial space.

Reviewer Comment (2018-06-01): XXXXXX has elected to waive this requirement based on compensating factors.

02/07/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

203612014

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.61280% is in excess of allowable threshold of Prime Mortgage Market Rate 3.52000% + 1.75%, or 5.27000%.  Compliant SubPrime Loan.

Reviewer Comment (2018-06-01): XXXXXX has elected to waive this exception.

02/08/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

B

B

A

A

Non QM

Non QM

No

203612092

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The subject property is located in a FEMA disaster that does not have a declared end date.

XXXXXX Wildfires, Flooding, Mudflows, and Debris Flows (DR-4353) Incident  Period [Redacted] Declared disaster [Redacted] No end date

Appraisal dated [Redacted] after disaster declared [Redacted].

Reviewer Comment (2018-06-01): XXXXXX has elected to waive with compensating factor.

04/04/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

203612092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

The Closing Date on Final Closing Disclosure is [Redacted]; the signature and notary dates are [Redacted].  A Post Consummation CD provided to the borrower did not correct the closing date error, changing it to [Redacted].

Reviewer Comment (2018-06-01): XXXXXX has elected to waive this exception.

04/04/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

203612092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

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

Missing evidence that the borrower was provided the closing disclosure at least 3 business days prior to closing

Reviewer Comment (2018-06-01): Seller provided the disclosure tracking for the initial CD dated  XXXXXX electronically received on  XXXXXX

04/04/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

203612092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD. (Fina [Redacted])

TRID non-compliant. Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure.  Seller CD fees total $[Redacted], while closing CD seller's fees total $0.00

Reviewer Comment (2018-06-01): XXXXXX has elected to waive this exception.

04/04/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

203612092

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrower is self employed 12 months ([Redacted]) vs program requirement that borrower must have been continuously self-employed for 2 years. Lender approved exception.

Excellent mortgage payment history, no late payments since inception. Borrower has job stability for 7 years as an [XXXXXX 36.254% DTI on this Alt documentation loan < 50% guideline max - 13.746% below program guideline maximum 704 FICO > 700 minimum required per program

Reviewer Comment (2018-06-01): XXXXXX has elected to waive this requirement based on compensating factors.

03/30/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Buyer Comment (2018-10-29): XXXXXX has elected to waive this exception.

10/05/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.40050% or Final Disclosure APR of 6.40500% is in excess of allowable threshold of APOR 3.86% + 2.5%, or 6.36000%.  Non-Compliant Higher Priced Mortgage Loan.

Verified fees were input correctly.

Reviewer Comment (2018-11-13): Received signed Acknowledgement of  receipt of appraisal dated XX5/17. Issue cleared.

11/13/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Secondary/XXXXXX)

Reviewer Comment (2018-11-13): Received signed Acknowledgement of  receipt of appraisal dated XX5/17. Issue cleared.

11/13/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML) California Higher-Priced Mortgage Loan (APR Exceeds HPML Threshold)

XXXXXX Higher-Priced Loan: APR on subject loan of 6.40050% or Final Disclosure APR of 6.40500% is in excess of allowable threshold of APOR 3.86% + 2.5%, or 6.36000%.  Compliant Higher Priced Loan.

Verified fees were input correctly.

Reviewer Comment (2018-10-29): XXXXXX purXXXXXXs HPML compliant loans.

11/24/2017

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Disclosure reflects Closing Date of (XXXXXX), but transaction consummation (mortgage notary) date was (XXXXXX).

Reviewer Comment (2018-10-29): XXXXXX has elected to waive this exception.

12/12/2017

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature. (Final/XXXXXX)

CD data field is blank.

Reviewer Comment (2018-10-29): XXXXXX has elected to waive this exception.

12/12/2017

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

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

Underdisclosed $2,520.  CD reflects $2,950 Lender Credits, however Lender paid fees are not designated.

Reviewer Comment (2019-09-06): Waived EV2/B Reviewer Comment (2018-10-29): Finance charges on PCCD remain under disclosed and were not corrected by the 2520. Exception remains open. Reviewer Comment (2018-10-29): PCCD does not address finance charge. Exception remains open.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for homeowner's insurance under Prepaids. (Final/XXXXXX)

CD data field is blank.

Reviewer Comment (2018-10-29): XXXXXX has elected to waive this exception.

12/12/2017

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

Reviewer Comment (2019-09-06): Waived EV2/B

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Cure for various 0% and 10% tolerance violations ($1,773.50) was not provided.

Reviewer Comment (2018-10-29): XXXXXX has elected to waive this exception. Reviewer Comment (2018-10-29): PCCD cleared the appraisal fee however additional 0% tolerance exceptions remain open.

12/12/2017

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

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

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2018-10-29): Seller provided the e-receipt for the initial CD XXXXXX.

12/12/2017

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $255.00 exceeds tolerance of $165.00 plus 10% or $181.50.  Insufficient or no cure was provided to the borrower. (0)

$73.50 tolerance violation due to increase in Title fees.

Reviewer Comment (2018-10-29): After review exception has been cleared.

12/12/2017

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Field Review Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (7310)

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2018-10-29): initial LE disclosed fee as CDA for 150 all other LE's and CD's disclosed as Appraisal field review. Reviewer Comment (2018-10-29): Appraisal field review fee of 150 was not included in the 1550 refunded in the check. Exception remains open. Reviewer Comment (2018-10-29): Seller provided PCCD however appraisal field review fee was not addressed. Exception remain open.

12/13/2017

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $2,200.00 exceeds tolerance of $650.00.  Insufficient or no cure was provided to the borrower. (7506)

Fee disclosed as ($650) on (LE dated XXXXXX), but disclosed as ($2,200.00) on Final Closing Disclosure.

Reviewer Comment (2018-10-29): Seller provided a corrected PCCD, refund, LOX and shipping label

12/12/2017

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

The borrower is self-employed.  Guidelines require either a tax professional letter or regulatory agency verifying at least 2 years of self-employment along with either a phone listing and/or business address using directory assistance or internet search to be in file.

Lender approved exception for CPA letter sets forth profit margin over one-year period while program requires 2 years.

Borrower has $183,677.14 in reserves.  Program requires minimum of $63,637.79. Borrower has been self employed since XXXXXX 38.02% DTI on this (Alt) documentation loan < 50% guideline max

Reviewer Comment (2018-10-29): XXXXXX has elected to waive this requirement based on compensating factors.

11/22/2017

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Courier, Storage and Wire Transfer fees reflected in section B, should be in section C.  Providers used are not listed on SSPL.

Reviewer Comment (2018-10-29): XXXXXX has elected to waive this exception.

12/12/2017

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

Credit Report: Original // Public Record Type: XXXXXX/ Balance: XXXXXX, Credit Report: Original // Public Record Type: XXXXXX / Balance: XXXXXX

Missing verification Liens have been satisfied.  Guidelines require Tax Liens to be paid off or satisfied prior to closing.

Buyer Comment (2018-10-29): XXXXXX has elected to waive this exception.

10/05/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

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

Reviewer Comment (2018-10-29): Seller provided the e-consent dated XXXXXX.

12/12/2017

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Courier / Express Mail / Messenger Fee.  Fee Amount of $35.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (75187)

Not disclosed on the LE in section B

Reviewer Comment (2019-09-06): Waived EV2/B Reviewer Comment (2018-10-29): Title - courier fee of $35.00 was not refunded in the 1550.00 refund. Exception remains open.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Electronic Document Delivery Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (75188)

Not disclosed on the LE in section B

Reviewer Comment (2019-09-06): Waived EV2/B Reviewer Comment (2018-10-29): Title - electronic document delivery fee of $25.00 was not refunded in the 1550.00 refund. Exception remains open.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $30.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (75206)

Not disclosed on the LE in section B

Reviewer Comment (2019-09-06): Waived EV2/B Reviewer Comment (2018-10-29): Title - wire fee of $30.00 was not refunded in the 1550.00 refund. Exception remains open.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on XXXXXX did not use the same fee terminology as the Loan Estimate. (Final/XXXXXX)

Initial CD disclosed CDA fee for 150.00 and all other LE's and CD's disclosed as Appraisal field review fee 150.00

Buyer Comment (2018-10-29): XXXXXX has elected to waive this exception.

10/05/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Transaction Error: Outstanding liens were not paid at closing.

Missing final title for evidence subject loan is in 1st place as no evidence lien paid off or released xxxx and xxxx.

Reviewer Comment (2018-11-01): Received final title showing subject lien in 1st position.

11/01/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

.

Reviewer Comment (2019-09-06): Waived EV2/B

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

.

Reviewer Comment (2019-09-06): Waived EV2/B

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on XXXXXX did not use the same fee terminology as the Loan Estimate.

.

Reviewer Comment (2019-09-06): Waived EV2/B

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

.

Reviewer Comment (2019-09-06): Waived EV2/B

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for homeowner's insurance under Prepaids.

.

Reviewer Comment (2019-09-06): Waived EV2/B

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

.

Reviewer Comment (2019-09-06): Waived EV2/B

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

204989204

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Missing approval

Reviewer Comment (2018-12-17): rec'd approval

12/17/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-01-04): Attestation approved by AMC in file. Reviewer Comment (2018-12-17): Please provide copy of broker agreement.  Unable to locate in file. Seller Comment (2018-12-11): We have provided our broker agreement which shows that all transactions are based on a set compensation and not subject to terms of the transaction

01/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

DTI, missing income documentation

Reviewer Comment (2019-08-12): Client approved exception to allow the co-borrower to be qualified with a 12-month average of the XX P&L statement only, which is not supported by the XX K-1 that reported a negative ordinary income not offset by distributions. Reviewer Comment (2019-06-06): Updated from: Ability to Repay (Dodd-Frank XX): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail. Reviewer Comment (2019-06-03): The loan has been submitted to elevated review. Seller Comment (2019-06-03): please review 2 uploads pending amc review and advise if this can be cleared. Reviewer Comment (2019-05-31): Unable to waive. Reviewer Comment (2019-04-26): Ok to waive per client. Reviewer Comment (2019-01-16): Information provided does not meet ATR requirements. Reviewer Comment (2018-12-17): Documentation provided does not meet ATR requirements. Seller Comment (2018-12-11): Documentation provided was acceptable, loan is still non-QM and not an ATR fail

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Missing third party verification.

Reviewer Comment (2019-01-16): Nothing provided to help clear ATR issue. Reviewer Comment (2018-12-13): .

12/13/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Missing third party verification.

Reviewer Comment (2018-12-13): .

12/13/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

DTI, missing income documentation

Reviewer Comment (2019-05-16): Rec'd tax returns / P&Ls

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX. (XXXXXX)

Missing most recent tax returns

Reviewer Comment (2018-12-13): . Seller Comment (2018-12-11): Documentation provided was acceptable, loan is still non-QM and not an ATR fail

12/13/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX. (XXXXXX)

Missing most recent tax returns

Reviewer Comment (2018-12-13): . Seller Comment (2018-12-11): Documentation provided was acceptable, loan is still non-QM and not an ATR fail

12/13/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

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

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Reviewer Comment (2018-12-12): Initial CD provided signed by the borrowers.

12/12/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX.

Reviewer Comment (2018-12-24): Lender provided Settlement Statement reflecting loan disbursed on 8/1/XX, which is more than 3 days after closing. Seller Comment (2018-12-11): see attached loan disbursed on 8/1/XX

12/24/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989204

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing gap report / credit refresh dated within 10 calendar days prior to closing.

Reviewer Comment (2018-12-17): rec'd credit refresh dated 7/XX18 Seller Comment (2018-12-11): this is in the file

12/17/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing compliance report.

Reviewer Comment (2018-12-17): rec'd compliance report Seller Comment (2018-12-11): this is in the file

12/17/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing rate lock.

Reviewer Comment (2018-12-17): rec'd rate lock Seller Comment (2018-12-11): this is in the file

12/17/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrower is not self-employed with XXXXXX  as indicated on the 1003 (K-1s reflect co-borrower as 60% owner and another party as 40% owner), but is a sole proprietor per XX & XX 1040s.  Missing third party verification of self-employment as well as XX and YTD XX P&L statements.

Reviewer Comment (2019-01-14): VVOE for borrower and secretary of state printout for XXXXXX in file. Reviewer Comment (2018-12-17): Rec'd P&L statements.  Still missing third party verification of all Schedule C businesses. Seller Comment (2018-12-11): this is in the file

01/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Self-employed borrowers.  Missing evidence of the existence of the business within 10 calendar days of closing verified through a disinterested third party such as CPA, regulatory agency, applicable licensing bureau, or verification of a phone and address listing using the internet.  Borrower:  Sole Proprietorship, Co-borrower: ELA Advertising and ELA Multicultural.

Reviewer Comment (2019-01-15): Rec'd printouts for  XXXXXX dated 7/XX18. Reviewer Comment (2018-12-17): Rec'd undated internet printout for XXXXXX.  Still missing evidence of the existence of XXXXXX dated within 10 calendar days prior to closing. Seller Comment (2018-12-11): this is in the file

01/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender used un-audited P&L statements in income calculations.  Audit income based on XX earnings, the most recent year of taxes filed.

Borrowers have 15.92 months reserves after closing vs guideline required 6 months Mortgage history is clean for 25 months

Originator Originator

Reviewer Comment (2019-08-12): Client approved exception to allow the co-borrower to be qualified with a 12-month average of the XX P&L statement only, which is not supported by the XX K-1 that reported a negative ordinary income not offset by distributions. Reviewer Comment (2019-06-03): The loan has been submitted to elevated review. Reviewer Comment (2019-05-23): Per guidelines, the use of the most recent P&L for qualifying may be considered if the tax returns have not been filed, if there is a strong rationale for the utilization of the income, and it is well-documented.  The borrower's XX income was $423K, XX was -$140K, and XX (per the unaudited P&L) is $862K.  It is not reasonable to assume that, after the XX loss, the income increased more than 200% from XX to XX.  Unable to include XX or XX P&L income. Seller Comment (2019-05-21): program guideline does not require audited p&l's Reviewer Comment (2019-05-16): Lender used a XX, XX & XX average of income for co-borrower from XXXXXX  Unable to include XX income, the P&L is not audited.  Review used XX income only, as there was a substantial decline from XX.  Lender income $22,566.73, review income ($11,675.70). Reviewer Comment (2019-01-16): Need 3rd party confirmation of P&L plus most recent tax year. Reviewer Comment (2018-12-17): Unable to use unaudited P&Ls in income calculations. Seller Comment (2018-12-11): P&L's aren't required to be audited per program guidelines

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX

Missing VVOE dated within 10 days of closing for borrower from XXXXXX

Reviewer Comment (2019-01-15): Rec'd printouts for  XXXXXX dated 7/XX18. Reviewer Comment (2018-12-17): Nothing provided. Seller Comment (2018-12-11): this is in the file

01/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX

Self-employed borrower.  Missing evidence of the existence of the business within 10 calendar days of closing verified through a disinterested third party such as CPA, regulatory agency, applicable licensing bureau, or verification of a phone and address listing using the internet.  ELA Advertising and ELA Multicultural.

Reviewer Comment (2019-01-15): Rec'd printouts for  XXXXXX dated 7/XX18.

01/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $44.95 exceeds tolerance of $25.00.  Insufficient or no cure was provided to the borrower. (7520)

There is no change of circumstance for the increased credit report fees.

Reviewer Comment (2018-12-13): AMC received VCC Reviewer Comment (2018-12-12): The Loan Estimates disclose a Credit Report of $25. The Final CD has 2 credit report fees that total $44.95.  Valid Change of circumstance not in loan file to justify additional credit report fee.  Cure required or additional information needs to be submitted to justify additional credit report being charged to the borrower. Seller Comment (2018-12-11): The credit report fee is $24.95 on the final CD

12/13/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Schedule C

Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income using reasonably reliable third-party records. (XXXXXX)

Missing third party verification of borrower's sole proprietorship.

Reviewer Comment (2018-12-13): .

12/13/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI, missing income documentation.

Reviewer Comment (2019-08-12): Client approved exception to allow the co-borrower to be qualified with a 12-month average of the XX P&L statement only, which is not supported by the XX K-1 that reported a negative ordinary income not offset by distributions. Reviewer Comment (2019-06-03): The loan has been submitted to elevated review. Reviewer Comment (2019-05-23): Per guidelines, the use of the most recent P&L for qualifying may be considered if the tax returns have not been filed, if there is a strong rationale for the utilization of the income, and it is well-documented.  The borrower's XX income was $423K, XX was -$140K, and XX (per the unaudited P&L) is $862K.  It is not reasonable to assume that, after the XX loss, the income increased more than 200% from XX to XX.  Unable to include XX or XX P&L income Seller Comment (2019-05-21): income documentation provided but p&ls not required to be audited per program guidelines Reviewer Comment (2019-05-16): DTI Reviewer Comment (2019-01-16): Missing all necessary income documentation to meet ATR requirements. Reviewer Comment (2019-01-09): Nothing uploaded. Reviewer Comment (2018-12-17): Documentation provided does not meet ATR requirements.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

The CD reflects XXXX18 whereas the notary date on the security instrument is XXXXXX.

Reviewer Comment (2018-12-13): .

12/13/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

$19.95

Reviewer Comment (2018-12-13): AMC received VCC Reviewer Comment (2018-12-12): The Loan Estimates disclose a Credit Report of $25. The Final CD has 2 credit report fees that total $44.95.  Valid Change of circumstance not in loan file to justify additional credit report fee.  Cure required or additional information needs to be submitted to justify additional credit report being charged to the borrower.

12/13/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989204

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing rate lock.

Reviewer Comment (2018-12-17): Rec'd rate lock.

12/17/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

.

Reviewer Comment (2019-05-16): Rec'd signed 1040s Reviewer Comment (2019-05-16): Missing signed 1040s or tax transcripts. Reviewer Comment (2019-01-15): Missing most recent tax year information.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

..

Reviewer Comment (2019-05-16): Rec'd signed 1040s Reviewer Comment (2019-05-16): Missing signed 1040s or tax transcripts. Reviewer Comment (2019-01-15): Missing most recent tax year information.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Schedule C

Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income using reasonably reliable third-party records. (XXXXX)

.

Reviewer Comment (2019-05-16): Rec'd tax returns / P&Ls Reviewer Comment (2019-01-15): Still missing most recent tax year information.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX. (XXXXXX)

..

Reviewer Comment (2019-01-22): Waive per client. Reviewer Comment (2019-01-16): Missing all necessary income documentation to meet ATR requirements. Reviewer Comment (2018-12-17): Documentation provided does not meet ATR requirements.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX. (XXXXXX)

.

Reviewer Comment (2019-01-22): Waive per client. Reviewer Comment (2019-01-15): Still need most recent tax year information or P&L done and provided by CPA.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Final CD shows closing date of XXXX18.  To cure an updated CD with the correct closing date and letter of explanation is required.

Reviewer Comment (2019-01-22): Waive per client. Reviewer Comment (2019-01-16): Please provide final settlement statement to show exact date for disbursement. Reviewer Comment (2018-12-20): The Close date indicated on the Final CD is XXXXXX however consummation date is XXXXXX. Please provide a corrected CD and LOE to cure.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989204

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

The most recent tax returns in file are XX.  XX extension provided.

Reviewer Comment (2019-08-07): EV2, Waived

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Lender's Approval was not provided.

Reviewer Comment (2019-01-10): Received

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Missing secondary valuation product required for securitization.

Second Valuation was not provided.

Reviewer Comment (2018-11-18): Rec'd Desk Review.

11/18/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.13790% or Final Disclosure APR of 6.21500% is in excess of allowable threshold of APOR 4.65% + 1.5%, or 6.15000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-04-23): Received initial appraisal report dated XXXXXX. Reviewer Comment (2019-01-10): Appraisal dated the same date as the Note date: XXXXXX Seller Comment (2019-01-09): Loan is Non-QM

04/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained prior to consummation.

Reviewer Comment (2019-04-23): Received initial appraisal report dated XXXXXX. Reviewer Comment (2019-02-11): The one full 1073 appraisal report in file (D0030) is dated 8/XXXX > = 8/XXXX Note date.  No additional full 1073 appraisal report(s) were in file for review.  Issue remains EV3 for appraisal not obtained prior to consummation. Seller Comment (2019-02-11): that was the revision that was needed not the initial appraisal Reviewer Comment (2019-01-10): Appraisal dated the same date as the Note date: XXXXXX Seller Comment (2019-01-09): the borrower received the appraisal 8/3/XX and the loan closing was 8/XXXX that is more than 3 days

04/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Personal 1040's were not provided. Income source verified through signed contracts and foreign income tax filings.

Reviewer Comment (2019-09-23): Stip clearing: XXXXXX approved an exception to allow the US Citizen's self-employed income to be verified with foreign income that was translated from XXXX to US dollars for XX, XX and XX, along with signed contracts and borrower-prepared P&L statement through XXXXXX. XXXXXX also approved an exception to allow the CPA letter as a 3rd party verification of self-employment even though the CPA letter is not on company letterhead and the CPA's license was not verified. XXXXXX guidelines are silent for US Citizen being qualified with foreign income and Fannie Mae guidelines require the last 2 years of signed personal tax returns, which have not been provided. Reviewer Comment (2019-06-07): XXXXXX underwriting guidelines defer to Fannie Mae standards when no guidelines are noted. In this case, the Permanent Resident Alien borrower was qualified with self-employed income from a foreign country. For foreign income to be considered, Fannie Mae requires 2 years signed federal tax returns which were not provided in the file. In addition, XXXXXX underwriting guidelines require a CPA letter (on company letterhead) from a professional based in the borrower's country of residence - Accountant/CPA/Financial Institution Officer/ Licensed Financial Advisor verifying both the nature of the business and income figures for the last 2 years and year-to-date income figure. CPA letter in file is not on company letterhead, the CPA license was not verified, the CPA did not verify both the nature of the business and income figures for the last 2 years, or provide a year-to-date income figure. File contains a borrower-prepared P&L statement that reflects gross income only for XX. In addition, foreign tax declarations for XX, XX and XX were not translated by the same CPA and file is missing the XX tax declaration. Exception remains for income not verified in accordance with XXXXXX and Fannie Mae guidelines. Seller Comment (2019-06-04): please review uploads Reviewer Comment (2019-05-31): Unable to waive. Reviewer Comment (2019-04-26): Ok to waive per client. Reviewer Comment (2019-04-23): The proper income documentation was not obtained at the time of origination or closing.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Schedule C

Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income using reasonably reliable third-party records. (XXXXXX)

Personal 1040's were not provided. Income source verified through signed contracts and foreign income tax filings.

Reviewer Comment (2018-11-18): Duplicate

11/18/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Personal 1040's were not provided. Income source verified through signed contracts and foreign income tax filings.

Reviewer Comment (2019-09-23): Stip clearing: XXXXXX approved an exception to allow the US Citizen's self-employed income to be verified with foreign income that was translated from Turkish Lira to US dollars for XX, XX and XX, along with signed contracts and borrower-prepared P&L statement through XXXXXX. XXXXXX also approved an exception to allow the CPA letter as a 3rd party verification of self-employment even though the CPA letter is not on company letterhead and the CPA's license was not verified. XXXXXX guidelines are silent for US Citizen being qualified with foreign income and Fannie Mae guidelines require the last 2 years of signed personal tax returns, which have not been provided. Reviewer Comment (2019-06-07): Exception is in relation to foreign income not verified in accordance with XXXXXX and Fannie Mae guidelines.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

No evidence of timely delivery was provided. Disclosure was not provided.

Reviewer Comment (2019-01-07): Attestation approved by AMC in file.

01/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 8/XXXX 12:00:00 AM was received. (Interim/XXXXXX)

There is no documentation in the loan file to determine that the borrower received the revised Loan Estimate prior to the Closing Disclosure issued on XXXXXX.

Reviewer Comment (2018-11-18): duplicate

11/18/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

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

There is no documentation in the loan file to determine that the borrower received the revised Loan Estimate at least four (4) business days prior to closing.

Reviewer Comment (2018-11-18): duplicate

11/18/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees seller paid fees do not match Consumer's Final CD

TILA-RESPA Integrated Disclosure: the Seller's final CD total seller paid fee amounts do not match the values used for compliance testing. (Final/XXXXXX)

Seller paid fees on Seller's Closing Disclosure are not consistent with those reflected on the Borrower's Final Closing Disclosure. Seller's CD reflects $37,790.42 in seller fees paid at closing. Borrower's final CD reflects $5,118.50 in seller paid fees at closing.

Reviewer Comment (2018-11-18): The final CD contains both borrower and seller fees.

11/18/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

204989395

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

Verification of Rent provided is not complete. Part 1- To (Name and Address of Landlord) is not complete. No landlord name or contact was provided. Unable to determine if verification was independently obtained. No record of form being mailed or faxed to landlord was provided.

Reviewer Comment (2019-01-10): Received updated document

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX

Reviewer Comment (2019-09-23): Duplicate to the ATR income docs exception. Reviewer Comment (2019-06-07): XXXXXX underwriting guidelines defer to Fannie Mae standards when no guidelines are noted. In this case, the Permanent Resident Alien borrower was qualified with self-employed income from a foreign country. For foreign income to be considered, Fannie Mae requires 2 years signed federal tax returns which were not provided in the file. In addition, XXXXXX underwriting guidelines require a CPA letter (on company letterhead) from a professional based in the borrower's country of residence - Accountant/CPA/Financial Institution Officer/ Licensed Financial Advisor verifying both the nature of the business and income figures for the last 2 years and year-to-date income figure. CPA letter in file is not on company letterhead, the CPA license was not verified, the CPA did not verify both the nature of the business and income figures for the last 2 years, or provide a year-to-date income figure. File contains a borrower-prepared P&L statement that reflects gross income only for XX. In addition, foreign tax declarations for XX, XX and XX were not translated by the same CPA and file is missing the XX tax declaration. Exception remains for income not verified in accordance with XXXXXX and Fannie Mae guidelines. Reviewer Comment (2019-05-15): Missing XX tax returns, third party verification. Seller Comment (2019-05-14): guidelines allow for 1 year tax returns - see attached Reviewer Comment (2019-02-14): Missing full two years of tax returns for full documentation loan.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Schedule C

Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income using reasonably reliable third-party records. (XXXXXX)

Personal 1040's were not provided. Income source verified through signed contracts and foreign income tax filings.

Reviewer Comment (2019-09-23): Stip clearing: XXXXXX approved an exception to allow the US Citizen's self-employed income to be verified with foreign income that was translated from Turkish Lira to US dollars for XX, XX and XX, along with signed contracts and borrower-prepared P&L statement through XXXXXX. XXXXXX also approved an exception to allow the CPA letter as a 3rd party verification of self-employment even though the CPA letter is not on company letterhead and the CPA's license was not verified. XXXXXX guidelines are silent for US Citizen being qualified with foreign income and Fannie Mae guidelines require the last 2 years of signed personal tax returns, which have not been provided. Reviewer Comment (2019-06-07): XXXXXX underwriting guidelines defer to Fannie Mae standards when no guidelines are noted. In this case, the Permanent Resident Alien borrower was qualified with self-employed income from a foreign country. For foreign income to be considered, Fannie Mae requires 2 years signed federal tax returns which were not provided in the file. In addition, XXXXXX underwriting guidelines require a CPA letter (on company letterhead) from a professional based in the borrower's country of residence - Accountant/CPA/Financial Institution Officer/ Licensed Financial Advisor verifying both the nature of the business and income figures for the last 2 years and year-to-date income figure. CPA letter in file is not on company letterhead, the CPA license was not verified, the CPA did not verify both the nature of the business and income figures for the last 2 years, or provide a year-to-date income figure. File contains a borrower-prepared P&L statement that reflects gross income only for XX. In addition, foreign tax declarations for XX, XX and XX were not translated by the same CPA and file is missing the XX tax declaration. Exception remains for income not verified in accordance with XXXXXX and Fannie Mae guidelines. Reviewer Comment (2019-05-15): Re-opened at client's request. Reviewer Comment (2019-04-26): The income used in qualifying does not meet XXXXXX guidelines set for a permanent resident alien and cannot be further verified independently as required by ATR.  Exception cannot be cured or cleared. Seller Comment (2019-04-23): The borrower moved to the US from a foreign country and purXXXXXXd a property prior to needing to file US tax returns - their foreign income was used to qualify them before it was necessary to claim it on a US return as they had not lived here yet. Reviewer Comment (2019-04-23): Per updated information provided, if borrower was a true permanent resident alien at the time of origination and closing, all applicable guidelines should have been followed.  Income from another country does not follow guidelines and cannot be verified with tax transcripts as again required per guidelines. Reviewer Comment (2019-02-14): The loan application lists the borrower as a permanent resident alien, not foreign national.  The loan is being done as a primary residence which is not allowed per guidelines on a foreign national borrower. Seller Comment (2019-02-11): this is a foreign national loan

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 8/XXXX 12:00:00 AM was received. (Interim/XXXXXX)

The file contains evidence of the LE sent to the borrower XXXX18.  Missing evidence of borrower's receipt prior to receipt of the CD issued XXXX18.

Reviewer Comment (2019-01-23): Waive per client. Reviewer Comment (2019-01-10): AMC is unable to waive exceptions if requested by seller. A client may waive exceptions. The initial CD was issued XXXXXX. The most recent CD was issued XXXXXX without indicating receipt therefore mailbox rule is used (XXXXXX). Exception must remain. Seller Comment (2019-01-09): borrower signed on 8/21 which is the 4 day wait from the LE - please waive

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

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

The file contains evidence of the LE sent to the borrower XXXX18.  Missing evidence of borrower's receipt of the revised LE at least 4 business days prior to closing.

Reviewer Comment (2019-04-23): Upon further review, the exception is cleared. Seller Comment (2019-04-23): I uploaded an email from our compliance team documenting the fact that if a borrower consented to receive disclosures electronically and we have that verified then all disclosures going forward would follow that rule.   If the revised LE was sent before the CD and we can document it was sent to an email where the borrower consented to receive disclosures we wouldnt follow the mail rule. Reviewer Comment (2019-04-23): AMC received evidence of receipt for the Initial LE dated XXXXXX.  The exception is pertaining to the XXXXXX Revised LE.  Evidence of receipt is required for the XXXXXX LE.  AMC is currently using the mailbox rule  which has the receipt date of XXXXXX and the CD was issued on XXXXXX which would be prior to the borrower receiving the revised loan estimate. Reviewer Comment (2019-01-10): AMC is unable to waive exceptions if requested by seller. A client may waive exceptions. The initial CD was issued XXXXXX. The most recent CD was issued XXXXXX without indicating receipt therefore mailbox rule is used (XXXXXX). Exception must remain. Seller Comment (2019-01-09): borrower signed 8/21 which is 4 days

04/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989395

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Most recent tax returns and foreign income tax returns are for XX.

Reviewer Comment (2019-09-23): Waive per client request.

09/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

204989408

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Approval was not provided.

Reviewer Comment (2019-01-10): Approval provided.

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989408

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees seller paid fees do not match Consumer's Final CD

TILA-RESPA Integrated Disclosure: the Seller's final CD total seller paid fee amounts do not match the values used for compliance testing. (Final/XXXXXX)

Seller CD reflects $50,643.49, Consumer CD reflects $8,393.49.

Reviewer Comment (2019-01-10): AMC received Seller's CD. Exception Cleared.

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989408

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Disclosure reflects Closing Date of XXXXXX, but transaction consummation (mortgage notary) date was XXXXXX.

Reviewer Comment (2019-01-10): XXXXXX closing documents are not date sensitive therefore it's ok if the borrower doesn't sign the date they're generated. - please waive AMC performs its file review in accordance with the SFIG RMBS 3.0 Compliance Review Scope. Under the SFIG Review Scope If the CD issued at docs becomes inaccurate, a corrected CD needs to be issued reflecting the actual terms of the transaction. Please provide corrected CD and LOE to cure. Reviewer Comment (2019-01-10): AMC performs its file review in accordance with the SFIG RMBS 3.0 Compliance Review Scope. Under the SFIG Review Scope If the CD issued at docs becomes inaccurate, a corrected CD needs to be issued reflecting the actual terms of the transaction. Please provide corrected CD and LOE to cure. Seller Comment (2019-01-09): XXXXXX closing documents are not date sensitive therefore it's ok if the borrower doesn't sign the date they're generated. - please waive

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989408

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

Aged document: Credit Report  is more than 90 days prior to the note date.

Credit Report: Original // Borrower: XXXXXX, Credit Report: Original // Borrower: XXXXXX

Reviewer Comment (2019-03-01): Credit refresh does show no major changes.  Pulled 8/XX18. Reviewer Comment (2019-01-10): An exception to use the expired credit report with credit refresh would be needed. Seller Comment (2019-01-09): because the credit was expired by only 2 days and the soft credit was pulled on the day it expired reflecting there were very minor changes if any the uw didn't require a repull

03/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989408

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX ___

Borrower was qualified under the 24 business bank statement program. 2 business accounts were used to validate P&L income. 1) XXXXXX  is missing statement ending in XXXX17, 2) Only 11 statements were provided for XXXXXX  with the most recent ending in XXXX18, more recent statements available and additional statements required to meet guidelines.

46.755 < 50% maximum DTI Borrowers have owned current property for 20 years 0x30 in 20 years of housing history.

Originator Aggregator Aggregator

Reviewer Comment (2019-03-06): Exception with compensating factors provided.

03/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989408

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Gift funds were not counted towards available reserves. Minimum reserve requirement was not met.

DTI 46.7% vs. max allowed of 50%. Borrowers have owned current property for 20 years 0x30 in 20 years of housing history.

Aggregator Aggregator Aggregator

Reviewer Comment (2019-03-06): Exception provided with compensating factors. Reviewer Comment (2019-01-10): Exception provided has compensating factors that are not sufficient.  Low DTI is not accurate as the guidelines state that the income is the lesser of the net from P&L or what was stated on initial 1003 therefore we used the income from the 1003 and the DTI is actually 46%.  Years on job is only 2.19 for both borrowers.  Insufficient compensating factors for reserves.  Would also need exception for credit report expiring prior to closing.

03/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989408

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering:  No Safe Harbor based on non-compliant Anti-Steering Disclosure

Loan Originator Compensation: Anti-Steering - No Safe Harbor based on non-compliant Anti-Steering Disclosure.

Reviewer Comment (2019-01-10): Attestation approved by AMC in file. Seller Comment (2019-01-09): We have provided our broker agreement which shows that all transactions are based on a set compensation and not subject to terms of the transaction

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989408

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-01-10): Attestation approved by AMC in file. Seller Comment (2019-01-09): We have provided our broker agreement which shows that all transactions are based on a set compensation and not subject to terms of the transaction

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989408

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

$150

Reviewer Comment (2019-01-10): AMC received XXXXXX COC. Exception Cleared.

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989408

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (75103)

A Change of Circumstance form in file does not provide a valid reason for the addition of the appraisal reinspection fee.

Reviewer Comment (2019-01-10): AMC received XXXXXX COC. Exception Cleared.

01/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989408

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing evidence borrowers are 100% owners of their businesses.

Reviewer Comment (2019-03-01): Secretary of State printout shows borrower  as CEO/CFO and co borrower as secretary. Reviewer Comment (2019-01-10): These documents are not enough to show proof of their individual ownership. Seller Comment (2019-01-09): The articles of incorporation are in the file which signify that Ike XXXXXX is the only agent and there is a business license for XXXXXX as she runs her own practice

03/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

204989408

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

XXXXXX closing documents are not date sensitive therefore it's ok if the borrower doesn't sign the date they're generated. - please waive AMC performs its file review in accordance with the SFIG RMBS 3.0 Compliance Review Scope. Under the SFIG Review Scope If the CD issued at docs becomes inaccurate, a corrected CD needs to be issued reflecting the actual terms of the transaction. Please provide corrected CD and LOE to cure.

Reviewer Comment (2019-01-23): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

204989411

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Lender's Loan Approval was not provided.

Reviewer Comment (2019-01-11): rec'd loan approval

01/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

C

A

Non QM

Non QM

No

204989411

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Missing secondary valuation product required for securitization.

Second Valuation was not provided.

Reviewer Comment (2018-10-29): Rec'd desk review.

10/21/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

C

A

Non QM

Non QM

No

204989411

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

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

Disclosure reflects finance charge of $xxxx but calculated finance charge is $xxxx, which is outside of $35.00 tolerance.  The index value used by lender is 2.803.  Used Index Value = 2.803% for testing.

Reviewer Comment (2019-01-11): Rate lock provided to show exact index value.

01/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

204989411

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (XXXXXX)

Loan is assumable under certain conditions. Assumable after fixed rate period.

Reviewer Comment (2019-01-11): Note verbiage is correct as CD is not.  Ok to waive per client. Reviewer Comment (2019-01-11): To remain EV2. Seller Comment (2019-01-10): This was a system glitch and has now been fixed - please waive

01/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

204989411

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $500.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing. (7506)

Lender provided a total of $50.00 cure and is reflected on Final Closing Consumer CD as a Lender Credit for increase in Closing Cost above legal limit.

09/24/2018

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Final CD evidences Cure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

204989411

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Loan exceeded 50.00% DTI. Lender's exception to allow 55.00% DTI was not provided.

46% LTV < 80% max. 8 mos. reserves > 6 mo minimum

Aggregator Aggregator

Reviewer Comment (2019-01-11): Rec'd exception for DTI XXXX

01/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

C

A

Non QM

Non QM

No

204989411

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (XXXXXX)

Note states yes, CD states no.

Reviewer Comment (2019-01-11): Ok to waive per client.

01/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

204989411

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

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

Finance charge on CD is $xxxx however system calculated finance charge is $xxxx.

Reviewer Comment (2019-02-28): XXXXXX received required documents; the exception is cleared. Seller Comment (2019-02-27): XXXXXX doesn't have the HOA fees for XXXX included in the APR fees. Also the Notary fee is not a finance charge. Fully indexed rate should be XXXX , current index is XXXX  .. please refer to the loan details that is in the file

02/28/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

204989411

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

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

Total finance percentage on CD is 117.19990% however system calculated percentage is 119.3500%

Reviewer Comment (2019-01-23): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

204989411

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

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

Total payment amount on CD is $xxxx however system calculated amount is $xxxx.

Reviewer Comment (2019-02-28): Upon further review, the exception is cleared.

02/28/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

204989508

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

The LLC Formation documents list a mailing address in the US.  Please confirm whether this is a local residence and if so, what the rent obligation is or confirm that this is not a residence occupied by the borrowers.  ( [Redacted])

Reviewer Comment (2018-10-29): The seller provided an Occupancy Affidavit

07/06/2018

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

A

C

A

A

A

A

A

N/A

N/A

No

204991193

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.04990% or Final Disclosure APR of 7.05700% is in excess of allowable threshold of APOR 4.65% + 1.5%, or 6.15000%.  Compliant Higher Priced Mortgage Loan.

Disclosure reflects APR as 7.057%; calculated is 7.0499%; threshold is 6.15%.

Reviewer Comment (2018-10-29): [Redacted] mortgage purXXXXXXs HPML compliant loans.

07/13/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

A

A

C

A

A

A

Non QM

Non QM

No

204991193

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML) California Higher-Priced Mortgage Loan (APR Exceeds HPML Threshold)

XXXXXX Higher-Priced Loan: APR on subject loan of 7.04990% or Final Disclosure APR of 7.05700% is in excess of allowable threshold of APOR 4.65% + 1.5%, or 6.15000%.  Compliant Higher Priced Loan.

Disclosure reflects APR as 7.057%; calculated is 7.0499%; threshold is 6.15%.

Reviewer Comment (2018-10-29): [Redacted] mortgage purXXXXXXs HPML compliant loans.

07/13/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

A

A

C

A

A

A

Non QM

Non QM

No

204991193

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Cure for various 0% tolerance violations $1,354.94 was not provided.

Reviewer Comment (2018-10-29): Seller provided the COC and lock confirmation for change in pricing due to loan changes in DTI. Reviewer Comment (2018-10-29): The seller supplied a detailed explanation as to the increase in fees but did not supply documentation the increase was disclosed to the borrower. Please provided Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected PCCD to cure the exception Reviewer Comment (2018-10-29): LE  [Redacted] loan amount  [Redacted] CD  [Redacted] loan amount  [Redacted] COC for  [Redacted] comments state loan amount increase - not valid as loan amount did not increase. Exception remains.

07/31/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

A

A

C

A

A

A

Non QM

Non QM

Yes

204991193

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $ [Redacted] exceeds tolerance of $ [Redacted].  Insufficient or no cure was provided to the borrower. (7200)

Loan Discount Points disclosed as $ [Redacted] on the LE dated  [Redacted] but disclosed as $ [Redacted]on the Final Closing Disclosure.

Reviewer Comment (2018-10-29): Seller provided the COC and lock confirmation for change in pricing due to loan changes in DTI. Reviewer Comment (2018-10-29): The seller supplied a detailed explanation as to the increase in fees but did not supply documentation the increase was disclosed to the borrower. Please provided Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected PCCD to cure the exception Reviewer Comment (2018-10-29): LE  [Redacted] loan amount  [Redacted] CD  [Redacted] loan amount  [Redacted] COC for  [Redacted] comments state loan amount increase - not valid as loan amount did not increase. Exception remains.

07/31/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

A

A

A

C

A

A

A

Non QM

Non QM

Yes

206257472

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Evidence borrower received the Home Loan Toolkit Disclosure was not provided in imaged file.

Buyer Comment (2019-03-01): XXXXXX has elected to waive.

09/20/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

B

B

B

A

B

B

A

A

Non QM

Non QM

No

206257472

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on XXXXXX was electronically provided prior to borrower's consent to receive electronic disclosures. (XXXXXX)

Borrower consented to electronic disclosures on XXXXXX however, Initial Loan Estimate was electronically provided to the borrower on XXXXXX.

Buyer Comment (2019-03-01): XXXXXX has elected to waive.

09/20/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

B

B

B

A

B

B

A

A

Non QM

Non QM

No

206257472

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

Credit Report: Original // Public Record Type: Collections / Balance: XXXXXX

Borrower's credit report reflects an undisputed, unpaid collection of $xxxx to XXXXXX dated XXXXXX that was not paid in full at closing and file does not contain evidence of payment in full prior to closing, as required by the Sales Guide (XXXXXX) for all non-medical collection accounts not in dispute.

Reviewer Comment (2019-03-01): Seller provided the credit supplement dated XXXX reflecting the collection paid in full. Buyer Comment (2019-03-01): Credit Supplement in file reflects collection paid in full. Please clear.

09/20/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

A

B

B

A

A

Non QM

Non QM

No

206257489

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/XXXXXX)

Valuation received XXXXXX < valuation report date XXXXXX.

Buyer Comment (2019-03-01): waive

10/09/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206257489

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-03-01): waive

10/09/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206257489

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (XXXXXX)

The final CD disclosed the the loan is not assumable; the note disclosed that the loan is assumable.

Reviewer Comment (2019-03-01): XXXXXX received Letter of Explanation & Corrected Closing Disclosure. Buyer Comment (2019-03-01): Uploaded PCCD/Refund

10/09/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206257489

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Figure not provided, field blank.

Reviewer Comment (2019-03-01): XXXXXX received valid shipping label. Exception Cured. Buyer Comment (2019-03-01): Uploaded UPS tracking Package is out for delivery today Reviewer Comment (2019-03-01): UPS shipping label XXXX created on XXXX  has not been shipped.  Exception cannot be cleared until package has been shipped. Buyer Comment (2019-03-01): Uploaded Shipping Label Reviewer Comment (2019-03-01): XXXXXX received XXXX  PCCD indicating cure. Please provide valid shipping label. Buyer Comment (2019-03-01): Uploaded corrected PCCD Reviewer Comment (2019-03-01): XXXXXX received a shipping label, LOE, non subject PCCD, and refund check. The shipping lable indicates package has not been mailed. The PCCD is not for subject property. Please provide Proof of Delivery and Corrected CD. Buyer Comment (2019-03-01): Uploaded PCCD/Refund

10/10/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206257489

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD. (XXXXXX)

Seller CD seller paid fees 55,556.00 > borrower CD seller paid fees 0.

Reviewer Comment (2019-03-01): XXXXXX received XXXX  PCCD. Seller paid fees are indicated on the Final CD. Exception Cleared. Buyer Comment (2019-03-01): Uploaded corrected PCCD Reviewer Comment (2019-03-01): XXXXXX received LOE, and non subject PCCD. Please provide Corrected CD. Buyer Comment (2019-03-01): Uploaded PCCD/Refund

10/09/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206257489

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Attorney Review Fee.  Fee Amount of $1,205.00 exceeds tolerance of $1,200.00.  Insufficient or no cure was provided to the borrower. (77166)

The CD issued on XXXXXX increased the Title - Attorney's Fees - Borrower's without a valid change of circumstance.

Reviewer Comment (2019-03-01): XXXXXX received valid shipping label. Exception Cured. Buyer Comment (2019-03-01): Uploaded UPS tracking Package is out for delivery today Reviewer Comment (2019-03-01): UPS shipping label XXXX  created on XXXX has not been shipped.  Exception cannot be cleared until package has been shipped. Buyer Comment (2019-03-01): Uploaded Shipping Label Reviewer Comment (2019-03-01): XXXXXX received XXXX  PCCD indicating cure. Please provide valid shipping label. Buyer Comment (2019-03-01): Uploaded corrected PCCD Reviewer Comment (2019-03-01): XXXXXX received a shipping label, LOE, non subject PCCD, and refund check. The shipping lable indicates package has not been mailed. The PCCD is not for subject property. Please provide Proof of Delivery and Corrected CD. Buyer Comment (2019-03-01): Uploaded PCCD/Refund

10/10/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206258001

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Reviewer Comment (2019-03-01): Corrected title commitment with coverage amount of XXXX  provided.

12/19/2018

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206258001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-03-01): XXXXXX has elected to waive this exception.

12/14/2018

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206258001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (XXXXXX)

Evidence of earlier receipt missing from file, initial CD issued XXXXXX not signed by borrower.

Reviewer Comment (2019-03-01): Received evidence of receipt. Cleared. Buyer Comment (2019-03-01): Please see ESIGN, and CD reflecting sent and received on XXXX

12/17/2018

1

A

XXXXXX

XXXXXX

Second Home

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206258001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

ATR fail due to short reserves, no lender exception in file.

Reviewer Comment (2019-03-01): Non QM per guidelines

12/14/2018

1

A

XXXXXX

XXXXXX

Second Home

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206258001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Qualification Method not Matching ATR

Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender does not match the ATR payment calculation methods under 1026.43(c)(5).

Custom XXXXXX I/O qualifying rate.

Buyer Comment (2019-03-01): XXXXXX has elected to waive this exception

12/19/2018

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206258001

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Borrower is short of 3 months required reserves for XXXXXX program, no lender exception in file.

Reviewer Comment (2019-03-01): Added appraisal and ins invoice to assets to satisfy reserve requirements. Buyer Comment (2019-03-01): Please see FINAL CD reflecting required CTC XXXX ; 3 months PITI XXXX results in required assets for closing and reserves totaling XXXX  Wire Report and XXXX Wire confirm XXXX in wire transfers have been received from the title company Buyer Comment (2019-03-01): Please see XXXX , XXXX  reflecting wires totaling XXXX  for CTC and reserves Reviewer Comment (2019-03-01): Added back prepaid homeowner's and appraisal fee, however borrower remains short of XXXX PITI by approximately XXXX . Buyer Comment (2019-03-01): Please see HOI paid on XXXX   - add back into available assets; Executed CD reflects XXXX  cash to close XXXX  EMD and two wires XXXX , and XXXX  have been sourced totaling XXXX

12/19/2018

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Reviewer Comment (2019-03-01): Appraisal provided. Buyer Comment (2019-03-01): Appraisal uploaded

12/19/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Appraisal missing from file.

Reviewer Comment (2019-03-01): Appraisal provided. Buyer Comment (2019-03-01): Appraisal uploaded, dated after XXXX

12/19/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Valuation:

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

Reviewer Comment (2019-03-01): Appraisal provided. Buyer Comment (2019-03-01): Appraisal uploaded

12/19/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.46810% or Final Disclosure APR of 9.52800% is in excess of allowable threshold of APOR 4.85% + 2.5%, or 7.35000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-03-01): Appraisal provided.

12/19/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Appraisal report missing from file.

Reviewer Comment (2019-03-01): Appraisal provided.

12/19/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Appraisal report missing from file.

Reviewer Comment (2019-03-01): Appraisal provided. Buyer Comment (2019-03-01): Appraisal uploaded.

12/19/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Appraisal report missing from file.

Reviewer Comment (2019-03-01): Appraisal provided. Buyer Comment (2019-03-01): Appraisal uploaded

12/19/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-03-01): XXXXXX has elected to waive this exception.

12/19/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (XXXXXX)

Fixed rate note with no assumption verbiage, final CD shows assumption is allowed.

Buyer Comment (2019-03-01): XXXXXX has elected to waive this exception.

12/19/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (XXXXXX)

Evidence of earlier receipt missing from file, initial CD not signed by borrower.

Reviewer Comment (2019-03-01): XXXXXX received Disclosure Tracking indicating the XXXX  CD was received the same day. Exception Cleared. Buyer Comment (2019-03-01): See attached CD Timing

12/20/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing

TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on XXXXXX contains a change in APR, loan product or addition of prepayment penalty and was not received by borrower at least three (3) business days prior to consummation

Evidence of earlier receipt missing from file, CD not signed by borrower.

Reviewer Comment (2019-03-01): XXXXXX received attestation from client indicating the XXXX CD's were for internal purposes only and were not sent to the borrower as disclosures. Buyer Comment (2019-03-01): The XXXX  CD were not sent to the borrower.  They were for internal purposes.

12/24/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXXX not received by borrower at least four (4) business days prior to closing. (XXXXXX)

Evidence of earlier receipt missing from file, final LE not signed by borrower.

Reviewer Comment (2019-03-01): XXXXXX received Disclosure Tracking indicating the XXXX  LE was received the same day, Exception Cleared. Buyer Comment (2019-03-01): See attached LE Timing

12/20/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $635.00 exceeds tolerance of $175.00.  Insufficient or no cure was provided to the borrower. (7726)

No cure provided for overage, endorsement fee increased without VCC.

Reviewer Comment (2019-03-01): XXXXXX received Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD. Buyer Comment (2019-03-01): PCCD documents uploaded for review.

12/24/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

Escrowed costs over 1 year is off due to HOI premium.  Monthly HOI per dec in file is $91.9XXmo. or $1103.00 annually.  Final CD shows monthly HOI is $92.00/mo.

Reviewer Comment (2019-03-01): XXXXXX received Letter of Explanation & Corrected Closing Disclosure. Buyer Comment (2019-03-01): PCCD documents uploaded.

12/24/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (XXXXXX)

Escrow payment off on CD.  Monthly HOI per dec in file is $91.9XXmo. or $1103.00 annually.  Final CD shows monthly HOI is $92.00/mo.

Reviewer Comment (2019-03-01): XXXXXX received  Letter of Explanation, Proof of Delivery, Corrected CD.

12/24/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (XXXXXX)

Payment off on CD.  Monthly HOI per dec in file is $91.9XXmo. or $1103.00 annually.  Final CD shows monthly HOI is $92.00/mo.

Reviewer Comment (2019-03-01): XXXXXX received Letter of Explanation, Proof of Delivery, Corrected CD.

12/24/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (XXXXXX)

12 months at $92.00/mo. should be $1104.00 but prepaid HOI is $1103.00, which matches declaration in file.

Buyer Comment (2019-03-01): XXXXXX has elected to waive this exception.

12/19/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Figure not provided, field blank.  No cure provided for endorsement fee overage.

Buyer Comment (2019-03-01): XXXXXX has elected to waive this exception.

12/19/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.46810% or Final Disclosure APR of 9.52800% is in excess of allowable threshold of APOR 4.85% + 2.5%, or 7.35000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-03-01): XXXXXX mortgage purXXXXXXs HPML compliant loans.

12/26/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $635.00 exceeds tolerance of $175.00.  Sufficient or excess cure was provided to the borrower. (7726)

Cure not provided

Reviewer Comment (2019-03-01): XXXXXX received required docuemnts, exception cured.

12/24/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

206258094

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: Closing Disclosure is incomplete

CD dated XXXXXX.

Reviewer Comment (2019-03-01): Page XXXX  of the XXXX  CD provided. Buyer Comment (2019-03-01): Please see attached page XXXX  of the XXXX  CD. Reviewer Comment (2019-03-01): Page XXXX  missing Buyer Comment (2019-03-01): Can you elaborate?  What is missing ?

12/26/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

206258100

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX

Missing the April XX business bank statement used for income analysis.

Reviewer Comment (2019-03-01): bank statements for April provided Buyer Comment (2019-03-01): See attached bank statements for April.  Borrower closed on account and opened XXXXXX

12/21/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

206258100

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.01810% or Final Disclosure APR of 7.05500% is in excess of allowable threshold of APOR 4.96% + 1.5%, or 6.46000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-03-01): XXXXXX mortgage purXXXXXXs HPML compliant loans.

12/20/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

206258100

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML) California Higher-Priced Mortgage Loan (APR Exceeds HPML Threshold)

XXXXXX Higher-Priced Loan: APR on subject loan of 7.01810% or Final Disclosure APR of 7.05500% is in excess of allowable threshold of APOR 4.96% + 1.5%, or 6.46000%.  Compliant Higher Priced Loan.

Reviewer Comment (2019-03-01): XXXXXX mortgage purXXXXXXs HPML compliant loans.

12/20/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

206258100

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Reviewer Comment (2019-03-01): Hazard Insurance policy does lists "Lender its successors and assigns", provided. Buyer Comment (2019-03-01): See attached

12/26/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

206315393

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Application / Processing

Missing Document: Missing Lender's Initial 1003

Reviewer Comment (2019-05-10): Initial 1003 provided Seller Comment (2019-05-09): HERE IS THE INSURANCE Seller Comment (2019-05-09): 1003

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206315393

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Adjustments

Excessive site value noted on appraisal without appraiser comments to justify

-

Reviewer Comment (2019-05-17): Appraiser did comment Seller Comment (2019-05-16): Under he cost approach section of the report the appraiser indicates "High site value ratio felt typical for the neighborhood for homes of the subject's size badsed on a comparison to the comps used in this report  (page 22)

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206315393

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2019-05-10): Replacement Cost Estimator documenting $xxxx replacement cost value provided.   $xxxx dwelling coverage > $387,964.00 replacement cost value

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206315393

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit

Reviewer Comment (2019-05-15): AMC received the following;  Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

05/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206315393

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Closing Protection Letter Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Title - Closing Protection Letter Fee. Fee Amount of $25.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-05-15): AMC received the following;  Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD. Seller Comment (2019-05-09): PCCD

05/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206315393

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Date Appraisal provided to borrower is not evident in the file.

Reviewer Comment (2019-05-10): D0125 Copy of appraisal e-mailed to Borrower 9/XXXX Seller Comment (2019-05-09): APPRAISAL DELIVERY

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206315393

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $15.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Title- Recording Service Fee was not disclosed on the initial LE but was added on the Final CD and the provider used was not the same provider used for the Title fees disclosed on the initial LE. It appears the borrower was not notified of the fee or given the opportunity to shop for a vendor so this fee is out of tolerance.

Reviewer Comment (2019-05-15): AMC received the following;  Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

05/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206315393

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Liquid reserves must be seasoned for a minimum of 3 months however, asset statements in file are only seasoned for 2 months.

Reviewer Comment (2019-05-10): Statements provided update several accounts.   Accounts not verified 3 months excluded from closing and reserves Seller Comment (2019-05-09): STATEMENTS

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206315393

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $15.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

AMC received the following;  Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

Reviewer Comment (2019-05-15): AMC received the following;  Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

05/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206315393

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Closing Protection Letter Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

AMC received the following;  Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

Reviewer Comment (2019-05-15): AMC received the following;  Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD.

05/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206337567

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-10-28): Receive the lender's mortgage commitment/approval.

10/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Borrower does not have the minimum active tradelines per guidelines.

Borrower does not meet tradeline requirement of 5 Credit Lines; Minimum 2 Active Credit Lines; At Least 1 Line with 24+ Month Rating. Only one active tradeline for the borrower according to the credit report dated XXXX18.

814 representative FICO score > 640 guideline minimum - 174 points above guideline minimum

Originator

Reviewer Comment (2019-10-28): Lender approved an exception to waive the tradeline requirement with one compensating factor.

10/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Per guidelines funds in the borrower's business account(s) ≤ 50% of account balance may be counted toward down payment, closing costs, and reserves. All funds appear to be coming from business accounts. Account XXXXXX bank printout reflects it is a business account however, does not reflect name on the account therefore, was treated as a business account and only 50% of funds was allowed to be used.

Reviewer Comment (2019-10-28): Received proof of the source for the large deposit of $8,100.00 into the borrower's business account. Borrower now has sufficient assets for closing. Reviewer Comment (2019-03-26): Received updated XXXXXX XXXXXX account summary and bank statements verifying $26,005.31 account balance (less $8,100.00 unsourced deposit made 2/8/XX) and that account is personal not business.    Issue remains EV3 for recalculated documented qualifying assets for closing of $23,146.07 is less than $24,119.73 cash required from Borrower. Seller Comment (2019-03-20): See attached personal savings account for XXXXX.  The account ending in XXXXX, the statements are provided, to supplement the statement a print out was provided (statement account ending number XXXXX) you can tie the statement and the print out together with the ending balance on the statement matching the print out balance and continuation.

10/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

PITIA reserves not met. Guidelines only allow 50% of business funds for closing and or reserves. No other assets were provided.

Reviewer Comment (2019-10-28): Received proof of the source for the large deposit of $8,100.00 into the borrower's business account. Borrower now has sufficient assets for reserves. Reviewer Comment (2019-03-26): Received updated XXXXXX XXXXXX account summary and bank statements verifying $26,005.31 account balance (less $8,100.00 unsourced deposit made 2/8/XX) and that account is personal not business.    Recalculated documented qualifying assets of $23,146.07 for closing and reserves.  Issue remains EV3 for 4 months verified PITI reserves Seller Comment (2019-03-20): See attached personal savings account for XXXXX.  The account ending in XXXXX, the statements are provided, to supplement the statement a print out was provided (statement account ending number XXXXX) you can tie the statement and the print out together with the ending balance on the statement matching the print out balance and continuation.

10/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-10-29): Waive per client request.

10/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

Colorado Home Loan (Tangible Net Benefit Disclosure Not Provided)

XXXXXX Home Loan (HB1322):  Loan file does not contain a Tangible Net Benefit Disclosure (or similar document).

Loan file does not contain a Tangible Net Benefit Disclosure (or similar document).

Reviewer Comment (2019-10-28): Received the Colorado Tangible Net Benefit Disclosure.

10/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Lump Sum Allocation

Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charges first, then finance charges pursuant to client's election as permitted under SFIG RMBS 3.0 TRID Compliance Review Scope Version 2.0 (updated October 2018).  Anti-predatory lending points and fees testing are not impacted.

Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charges first, then finance charges pursuant to client's election as permitted under SFIG RMBS 3.0 TRID Compliance Review Scope Version 2.0

Reviewer Comment (2019-10-28): Upon a rerun of compliance, this exception has been cleared.

10/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for various 0% and 10% tolerance violations $1,386.90 was not provided.

Reviewer Comment (2019-04-04): Services borrower could shop for and chose outside company.

04/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Borrower not provided with list of service providers.

Reviewer Comment (2019-03-26): List of Service Providers provided (D0118).  Integrated Disclosure screen (Used Vendor on SSPL field) completed

03/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,407.00 exceeds tolerance of $541.00 plus 10% or $595.10.  Insufficient or no cure was provided to the borrower.

$811.90 violation due to increase in Lender's Title Insurance and Recording Service Fee. SSPL not evident in the file.

Reviewer Comment (2019-03-26): List of Service Providers provided (D0118).  Integrated Disclosure screen (Used Vendor on SSPL field) completed

03/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee.  Fee Amount of $300.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Missing SSPL therefore, unable to test fee and tolerance is valid.

Reviewer Comment (2019-03-26): List of Service Providers provided (D0118).  Integrated Disclosure screen (Used Vendor on SSPL field) completed

03/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $120.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Title- Wire/Funding/Disbursement Fee was not disclosed on the initial LE but was added on the Final CD and the provider used was not the same provider used for the Title fees disclosed on the initial LE. It appears the borrower was not notified of the fee or given the opportunity to shop for a vendor so this fee is out of tolerance.

Reviewer Comment (2019-04-04): Services borrower could shop for and chose outside company.

04/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Release Tracking Fee.  Fee Amount of $80.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Erroneous Reg ID 3061.  This fee seller paid, and is customarily paid by Seller in the state of CO.

Reviewer Comment (2019-04-04): Services borrower could shop for and chose outside company.

04/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Missing SSPL therefore, unable to test fee and tolerance is valid.

Reviewer Comment (2019-03-26): List of Service Providers provided (D0118).  Integrated Disclosure screen (Used Vendor on SSPL field) completed

03/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Letter from broker to lender transferring appraisal is not evident.

Reviewer Comment (2019-10-29): Received the appraisal transfer letter from broker name to lender.

10/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206337567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Tax Certificate Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Missing SSPL therefore, unable to test fee and tolerance is valid.

Reviewer Comment (2019-03-26): List of Service Providers provided (D0118).  Integrated Disclosure screen (Used Vendor on SSPL field) completed

03/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.59110% or Final Disclosure APR of 7.73800% is in excess of allowable threshold of APOR 4.48% + 1.5%, or 5.98000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): XXXXXX mortgage purXXXXXXs HPML compliant loans.

02/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

206889253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Lump Sum Allocation

Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charges first, then finance charges pursuant to client's election as permitted under SFIG RMBS 3.0 TRID Compliance Review Scope Version 2.0 (updated October 2018).  Anti-predatory lending points and fees testing are not impacted.

Buyer Comment (2019-05-31): XXXXXX has elected to waive

02/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

206889256

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/XXXXXX)

Appraisal receipt dated XXXXXX report date XXXXXX.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception

02/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889256

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.20220% or Final Disclosure APR of 7.24600% is in excess of allowable threshold of APOR 4.81% + 1.5%, or 6.31000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): XXXXXX mortgage purXXXXXXs HPML compliant loans.

02/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889256

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception

02/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889256

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Closing Disclosure Lump Sum Allocation

Lump sum lender/seller credit disclosed on Closing Disclosure applied to offset non-finance charges first, then finance charges pursuant to client's election as permitted under SFIG RMBS 3.0 TRID Compliance Review Scope Version 2.0 (updated October 2018).  Anti-predatory lending points and fees testing are not impacted.

Buyer Comment (2019-05-31): XXXXXX Mortgage has elected to waive this exception Reviewer Comment (2019-05-31): There is nothing required to re mediate this exception. it is an open EV2. IT can remain open or client can opt to waive the exception. it merely clarifies the method employed by client to allocate lump sum credits. Buyer Comment (2019-05-31): Seller's CD uploaded

02/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889256

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

The interim CDs dated XXXXXXdisclosed seller paid fees; however, the final CD did not disclose any seller paid fees.  A Seller's CD was not provided.

Reviewer Comment (2019-05-31): XXXXXX received Seller's CD. Exception Cleared. Buyer Comment (2019-05-31): Uploaded For Your Review: Seller CD

02/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206889256

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

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

The earliest ARM disclosure date is XXXXXX; the application was received on XXXXXX.

Reviewer Comment (2019-05-31): Initial ARM loan program disclosure provided Buyer Comment (2019-05-31): Uploaded For Review: Arm Disclosure

02/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889257

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.50410% or Final Disclosure APR of 7.55500% is in excess of allowable threshold of APOR 4.84% + 1.5%, or 6.34000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): XXXXXX mortgage purXXXXXXs HPML compliant loans.

02/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889257

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.

Disclosure provided on XXXXXX; application received XXXXXX.

Buyer Comment (2019-05-31): XXXXXX has elected to waive

02/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889257

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Disclosure provided on XXXXXX; application received XXXXXX.

Buyer Comment (2019-05-31): XXXXXX has elected to waive

02/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889257

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.50410% is in excess of allowable threshold of Prime Mortgage Market Rate 3.90000% + 1.75%, or 5.65000%.  Compliant SubPrime Loan.

Buyer Comment (2019-05-31): XXXXXX has elected to waive

02/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889257

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature. (XXXXXX)

The final CD did not have a box checked in the Demand Feature section of the Loan  Disclosures.

Buyer Comment (2019-05-31): XXXXXX has elected to waive

02/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206889257

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

No tolerance cure provided on the CD.

Buyer Comment (2019-05-31): XXXXXX has elected to waive

02/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206889257

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $10,875.00 exceeds tolerance of $10,000.00.  Insufficient or no cure was provided to the borrower. (7200)

COC provided and documented, however closing date on XXXXXX CD states XXXXXX -unable to re-baseline.

Reviewer Comment (2019-05-31): Change of circumstance provided  - loan amount increase - lender provided attestation confirming the closing date on the revised cd issued on XXXX Reviewer Comment (2019-05-31): XXXXXX received a Lender Attestation citing an incorrect issue date of XXXX  there is not a CD with a date in XXXX  The CD in question was issued on XXXX with a closing date of XXXX .  Please provide an attestation letter to clear with the facts surrounding the interim CD issued on XXXX . Reviewer Comment (2019-05-31): lender provided an attestation for the CD issuedXXXX  we need an attestation for the CD issuedXXXX   CD issued dated XXXX  has a closing date of XXXX .  Lender to provide attestation on what the correct closing date should have been in order to re baseline for the loan amount increase Reviewer Comment (2019-05-31): The issue here is that both the initial and interim CDs dated XXXX  and XXXX have a closing date of XXXX  and are being tested as a post close CD, then there is the final CD on XXXX  which corrected the closing date toXXXX .  Since the Loan Discount Point and the Transfer Tax fees cannot be rebaselined due to closing date on those CDs, a refund is due. Buyer Comment (2019-05-31): The coc for the increase in fees from XXXX to XXXX  is in the efolder the loan amount increased which increased the points.  That should fix that one.  That should also fix the transfer tax increase as that was a result of the loan amount increase as well.

02/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206889257

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXX exceeds tolerance of $3,362.00.  Insufficient or no cure was provided to the borrower. (8304)

No VCC provide for the Transfer Tax change

Reviewer Comment (2019-05-31): Change of circumstance provided  - loan amount increase - lender provided attestation confirming the closing date on the revised cd issued on XXXX Reviewer Comment (2019-05-31): XXXXXX received a Lender Attestation citing an incorrect issue date of XXXX , there is not a CD with a date in XXXX .  The CD in question was issued on XXXX with a closing date of XXXX   Please provide an attestation letter to clear with the facts surrounding the interim CD issued on XXXX Reviewer Comment (2019-05-31): lender provided an attestation for the CD issued XXXX  we need an attestation for the CD issued XXXX   CD issued dated XXXX  has a closing date of XXXX .  Lender to provide attestation on what the correct closing date should have been in order to re baseline for the loan amount increase Reviewer Comment (2019-05-31): The issue here is that both the initial and interim CDs dated XXXX  and XXXX  have a closing date of XXXX  and are being tested as a post close CD, then there is the final CD on XXXX  which corrected the closing date to XXXX   Since the Loan Discount Point and the Transfer Tax fees cannot be rebaselined due to closing date on those CDs, a refund is due. Buyer Comment (2019-05-31): The coc for the increase in fees from XXXX to XXXX is in the efolder the loan amount increased which increased the points.  That should fix that one.  That should also fix the transfer tax increase as that was a result of the loan amount increase as well.

02/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206889259

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.77640% or Final Disclosure APR of 8.79200% is in excess of allowable threshold of APOR 4.89% + 1.5%, or 6.39000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): XXXXXX mortgage purXXXXXXs HPML compliant loans.

02/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889259

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

02/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889259

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

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

Initial CD issued XXXXXX was not signed/dated as received by borrower. Default date used of XXXXXX.  Actual closing date is XXXXXX

Reviewer Comment (2019-05-31): XXXXXX received Disclosure Tracking indicating the CD was received XXXX . Exception Cleared. Buyer Comment (2019-05-31): CD tracking uploaded for review.

02/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889259

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXXX not received by borrower at least four (4) business days prior to closing.

LE issued XXXXXX was not signed/dated as received by borrower. Default date used of XXXXXX.

Reviewer Comment (2019-05-31): XXXXXX received Disclosure Tracking indicating the LE was received XXXX  Exception Cleared. Buyer Comment (2019-05-31): LE tracking uploaded for review.

02/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State High Cost) New York High-Cost Loan (Points and Fees)

XXXXXX Anti-Predatory Lending Statute: Points and Fees on subject loan of XXXX% is in excess of the allowable maximum of  5.00000% of the Total Loan Amount. Points and Fees total $XXXXX on a Total Loan Amount of $XXXXXX vs. an allowable total of $XXXXX (an overage of $XXX or .17237%).  Compliant High Cost Loan.

Reviewer Comment (2019-05-31): Verified delivery of refund check on XXXX Buyer Comment (2019-05-31): See trailing documents. Reviewer Comment (2019-05-31): An overage of XXXX  or XXXX does exist. Provided copy of check, along with LOE, tracking information and PCCD. Buyer Comment (2019-05-31): Please confirm cure refund of XXXX , PCCD, LOE and tracking will bring within tolerance?

02/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $16,509.94 may be required.

Missing documentation.

Reviewer Comment (2019-05-31): XXXXXX received XXXX  LE. Exception Cleared. Reviewer Comment (2019-05-31): XXXXXX received the XXXX LE. Please provide all prior LEs to complete compliance testing. Buyer Comment (2019-05-31): See trailing document

02/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Missing documentation.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

02/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/XXXXXX)

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2019-05-31): XXXXXX received XXXX  CD received the same day. Exception Cleared. Buyer Comment (2019-05-31): See trailing documents

02/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.10320% or Final Disclosure APR of 7.13500% is in excess of allowable threshold of APOR 4.89% + 1.5%, or 6.39000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): XXXXXX mortgage purXXXXXXs HPML compliant loans.

02/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Lender approved exception to allow DTI over program maximum of 43%

Reviewer Comment (2019-05-31): Allow for DTI up to XXXX vs program max of XXXX Buyer Comment (2019-05-31): Updated XXXXXX Credit Exception provided. Please re-grade / clear.

02/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 46.45860% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Lender approved exception for 44.544% to allow DTI over program maximum of 43% however reviewer calculation at 46.4586% please provide a revised lender exception for updated DTI.

Excellent payment history no late payments on credit report since inception with earliest open date of XXXXXX. No public rerecords. Borrower has been self employed as owner of XXXXXX for the past 7.08 years and 30 years in the same profession. 6.36 months reserves > 3 months guideline minimum Credit score 737, 27 points > program requirement of 720.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): Allow for DTI up to XXXX  vs program max of XXXX Buyer Comment (2019-05-31): Updated XXXXXX Credit Exception provided. Please re-grade / clear.

02/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender approved exception for 44.544% to allow DTI over program maximum of 43% however reviewer calculation at 46.4586% please provide a revised lender exception for updated DTI.

Excellent payment history no late payments on credit report since inception with earliest open date of XXXXXX. No public rerecords. Borrower has been self employed as owner of XXXXXX for the past 7.08 years and 30 years in the same profession. 6.36 months reserves > 3 months guideline minimum Credit score 737, 27 points > program requirement of 720.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): Allow for DTI up to XXXX vs program max of XXXX Buyer Comment (2019-05-31): See Revised / Approved XXXXXX Exception uploaded

02/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.10320% is in excess of allowable threshold of Prime Mortgage Market Rate 3.90000% + 1.75%, or 5.65000%.  Compliant SubPrime Loan.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

02/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Lender approved exception for 44.544% to allow DTI over program maximum of 43% however reviewer calculation at 46.4586% please provide a revised lender exception for updated DTI.

Reviewer Comment (2019-05-31): Allow for DTI up toXXXX vs program max of XXXX

02/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

XXXXXX received XXXXXX LE. Please provide all prior LEs to determine if exception can be cleared.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

02/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/XXXXXX)

XXXXXX received XXXXXX LE. Please provide all prior LEs to determine if exception can be cleared.

Reviewer Comment (2019-05-31): XXXXXX received initial LE dated XXXX Buyer Comment (2019-05-31): See trailing document

02/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

XXXXXX received XXXXXX LE and prior CDs. Please provide SSPL.

Reviewer Comment (2019-05-31): SSPL provided.

02/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

XXXXXX received XXXXXX LE and CDs. Please provide SSPL to determine if exception can be cleared.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

02/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Survey Fee.  Fee Amount of $110.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (77187)

XXXXXX received XXXXXX LE and CDs. Please provide SSPL to determine if exception can be cleared.

Reviewer Comment (2019-05-31): XXXXXX received initial LE dated XXXX Buyer Comment (2019-05-31): See trailing document provided.

02/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Policy Guarantee Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (77223)

XXXXXX received XXXXXX LE and CDs. Please provide SSPL to determine if exception can be cleared.

Reviewer Comment (2019-05-31): XXXXXX received initial LE dated XXXX Buyer Comment (2019-05-31): See trailing document provided.

02/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Services Sales Tax.  Fee Amount of $54.94 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (77239)

XXXXXX received XXXXXX LE and CDs. Please provide SSPL to determine if exception can be cleared.

Reviewer Comment (2019-05-31): XXXXXX received initial LE dated XXXX Buyer Comment (2019-05-31): See trailing document provided.

02/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Abstract / Title Search.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (7754)

XXXXXX received XXXXXX LE and CDs. Please provide SSPL to determine if exception can be cleared.

Reviewer Comment (2019-05-31): XXXXXX received initial LE dated XXXX Buyer Comment (2019-05-31): See trailing document provided.

02/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Survey Fee.  Fee Amount of $110.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (77187)

.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception. Reviewer Comment (2019-05-31): XXXXXX received PCCD, Copy of Refund check in the amount of XXXX  letter of explanation and shipping label with Fedex tracking XXXX   However, package has not yet shipped.  Provide proof of delivery to cure.

02/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Policy Guarantee Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (77223)

.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

02/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Services Sales Tax.  Fee Amount of $54.94 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (77239)

.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

02/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Abstract / Title Search.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower. (7754)

.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception. Reviewer Comment (2019-05-31): XXXXXX received PCCD, Copy of Refund check in the amount of XXXX , letter of explanation and shipping label with Fedex tracking XXXX .  However, package has not yet shipped.  Provide proof of delivery to cure.

02/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889272

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Missing evidence of the borrower's receipt of the Anti-Steering Disclosure.

Reviewer Comment (2019-05-31): The buyer has elected to waive this exception. Buyer Comment (2019-05-31): Please waive

12/20/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889272

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.89120% or Final Disclosure APR of 7.92500% is in excess of allowable threshold of APOR 4.88% + 1.5%, or 6.38000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): XXXXXX mortgage purXXXXXXs HPML compliant loans.

12/19/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889272

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence of the borrower's receipt of the LO Compensation disclosure.

Reviewer Comment (2019-05-31): The buyer has elected to waive this exception. Buyer Comment (2019-05-31): Please waive

12/20/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889272

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

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

Disclosure reflects Finance Charge of ($xxxx) but calculated Finance Charge is ($xxxx). Under disclosed by $250.00.

Reviewer Comment (2019-05-31): XXXXXX received Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and evidence package has been shipped. Buyer Comment (2019-05-31): UPS Tracking Reviewer Comment (2019-05-31): XXXXXX received PCCD, LOE, Copy of Refund Check and copy of UPS tracking XXXX  Shipping label has been created, but not yet shipped.  Please provide evidence of Proof of Delivery to cure. Buyer Comment (2019-05-31): PCCD,LOX,Label,Check Buyer Comment (2019-05-31): PCCD,LOX,Label, Buyer Comment (2019-05-31): PCCD,LOX, Reviewer Comment (2019-05-31): XXXXXX received Post Close CD, LOE to borrower, Proof of Delivery and Cure check for XXXX   The finance charge under disclosed by XXXX   Additional cure check for XXXX , Corrected CD, LOE to borrower and proof of delivery required. Buyer Comment (2019-05-31): PCCD,LOX,Check,UPS Label Buyer Comment (2019-05-31): PCCD,LOX,Check, Buyer Comment (2019-05-31): PCCD,LOX Buyer Comment (2019-05-31): PCCD, Reviewer Comment (2019-05-31): Finance charge exception is caused by a fee or a combination of fees that increased the calculated finance charge.  It appears the Lender may not have included the Final Inspection Fee of XXXX  and second Administration fee of XXXX  in Section B.  Neither of these fees are listed on the compliance report.  Please have the Lender verify the fees they included in the FC calculation. Reviewer Comment (2019-05-31): Under disclosed amount is not due to fees however is due to the amount of finance charges on the final CD page 4 of XXXX . difference of XXXX . (edited) Reviewer Comment (2019-05-31): Calculated finance charge matches the compliance report of XXXX .  Final CD indicates finance charge is XXXX Buyer Comment (2019-05-31): Please provide what Fee is under disclosed

01/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206889272

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (XXXXXX)

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2019-05-31): XXXXXX received Disclosure Tracking indicating the XXXX  CD was received the same day. Exception Cleared. Buyer Comment (2019-05-31): CD Tracking

12/26/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889272

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Cure for (Title - Endorsement Fee) of ($169.90) was not provided.

Reviewer Comment (2019-05-31): CD input is updated. Exception Cleared.

12/26/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206889272

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $194.90 exceeds tolerance of $25.00.  Insufficient or no cure was provided to the borrower. (7726)

Fee disclosed as ($25) on (LE dated XXXXXX), but disclosed as ($194.90) on Final Closing Disclosure.

Reviewer Comment (2019-05-31): CD input is updated. Exception Cleared. Buyer Comment (2019-05-31): There is no Endorsement Fee on the Final CD

12/26/2018

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

206889272

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure XXXXXX 12:00:00 AM was received. (XXXXXX)

The most recent LE dated XXXXXX does not indicate receipt therefore the mailbox rule is used with a receipt date of XXXXXX.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception Buyer Comment (2019-05-31): Please waive

12/28/2018

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Please provide Final Approval.

Reviewer Comment (2019-05-31): Final approval has been provided.

03/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Please provide 2 months bank statements for accounts listed on Final 1003 supporting figures used to qualify. Subject to re-qualification.

Reviewer Comment (2019-05-31): Additional account provided. Reviewer Comment (2019-05-31): Need CPA letter reflecting Grinding Services as well and the usability of funds from business account. Buyer Comment (2019-05-31): Only one account used to qualify

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Please provide 2 months bank statements for accounts listed on Final 1003 supporting figures used to qualify. Subject to re-qualification.

Reviewer Comment (2019-05-31): Additional account provided. Buyer Comment (2019-05-31): please see uploaded 2nd page of 1003 and bank statement

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.37430% or Final Disclosure APR of 7.38100% is in excess of allowable threshold of APOR 4.82% + 2.5%, or 7.32000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): .

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Closing Costs Financed

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.

Disclosure reflects $0 for Closing Costs Financed, but this should be ($16,263.27).

Buyer Comment (2019-05-31): XXXXXX has elected to waive

03/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $13,828.44 may be required.

Missing evidence of the borrower's receipt of the Loan Estimate.

Reviewer Comment (2019-05-31): Initial LE provided

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Missing evidence of the borrower's receipt of the ARM Disclosure.

Reviewer Comment (2019-05-31): .

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Missing evidence of the borrower's receipt of the Consumer Handbook on Adjustable Rate Mortgages.

Reviewer Comment (2019-05-31): CHARM Booklet Disclosure provided

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing evidence of the borrower's receipt of the Right to receive a copy of the Appraisal Disclosure.

Reviewer Comment (2019-05-31): Evidence of the borrower's receipt of the Right to receive a copy of the Appraisal Disclosure provided.

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing evidence of the borrower's receipt of the Right to receive a copy of the Appraisal Disclosure.

Reviewer Comment (2019-05-31): .

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Missing evidence of the borrower's receipt of the Servicing Disclosure.

Reviewer Comment (2019-05-31): Initial LE provided

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2019-05-31): .

03/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender approved exception to allow DTI is 53.319% vs program maximum of 50%. Please provide updated exception for 53.40516% as calculated per final amounts.

No public records. Subject has undergone renovations since purchase with new baths, paint, custom doors, hardwood floors and a refinished fireplace. Rate and term refinance. Credit score is 676, 36 points < program requirement of 640. LTV is 79.048%, 5.952% < program maximum of 85%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): DTI is XXXX  vs program max XXXX Reviewer Comment (2019-05-31): Updated DTI is XXXX Buyer Comment (2019-05-31): please see uploaded 2nd page of 1003 and bank statement

03/14/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Lender approved exception to allow DTI is 53.319% vs program maximum of 50%. Please provide updated exception for 53.40516% as calculated per final amounts.

Reviewer Comment (2019-06-04): Diligence designation is now Non-QM Reviewer Comment (2019-05-31): DTI is XXXX  vs program max XXXX Reviewer Comment (2019-05-31): Updated DTI is XXXX Buyer Comment (2019-05-31): please see uploaded 2nd page of 1003 and bank statement

06/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Lender approved exception to allow DTI is 53.319% vs program maximum of 50%. Please provide updated exception for 53.40516% as calculated per final amounts.

Reviewer Comment (2019-05-31): DTI is XXXX vs program max XXXX Reviewer Comment (2019-05-31): Updated DTI is XXXX Buyer Comment (2019-05-31): please see uploaded 2nd page of 1003 and bank statement

03/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 53.40516% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Lender approved exception to allow DTI is 53.319% vs program maximum of 50%. Please provide updated exception for 53.40516% as calculated per final amounts.

No public records. Subject has undergone renovations since purchase with new baths, paint, custom doors, hardwood floors and a refinished fireplace. Rate and term refinance. Credit score is 676, 36 points < program requirement of 640. LTV is 79.048%, 5.952% < program maximum of 85%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): DTI is XXXX vs program max XXXX Reviewer Comment (2019-05-31): Updated DTI is XXXX Buyer Comment (2019-05-31): please see uploaded 2nd page of 1003 and bank statement

03/14/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Third Circuit)

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.

Subject is a same Lender refinance with the H-8 form used.

Reviewer Comment (2019-05-31): RTC Due to same lender refi, form H-9 provided. Reviewer Comment (2019-05-31): Due to same lender refi, form needs to be H-9. Buyer Comment (2019-05-31): Please advise what is wrong with current RTC

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

Please provide verification of cancelled checks for current subject mortgage payments. Per guidelines for obligations not appearing on credit report, verification of mortgage or copies of the front and back of the last months checks. File contains a spreadsheet listing payment history (document is not from the Lender) and copies of checks (checks are not cancelled checks and no bank statements in file to supporting clearing account). Subject to re-qualification.

Reviewer Comment (2019-05-31): Agree with lender. Buyer Comment (2019-05-31): Property was acquired in XXXX  with first payment in XXXX . Please advise what months you are missing. I submitted cancelled checks from XXXX Reviewer Comment (2019-05-31): No new documentation has been provided in trailing docs to support 6 month history. Reviewer Comment (2019-05-31): Trailing docs only shows 2 months of cancelled checks.

03/13/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $13,828.44 and disclosure timing violations.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX  Exception Cleared.

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Buyer Comment (2019-05-31): XXXXXX has elected to waive

03/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

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

Please provide Settlement Service Provider List. Document provided list the fees and cost of the fees but does not provide a name and contact information for settlement providers

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX . Exception Cleared.

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,878.00 exceeds tolerance of $0.00 plus 10% or $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX . Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Application Fee.  Fee Amount of $550.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX  Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Commitment Fee.  Fee Amount of $XXXX exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX . Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $575.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee.  Fee Amount of $160.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX . Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Compliance Audit / Quality Control Fee.  Fee Amount of $165.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX  Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $32.44 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX  Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Fee.  Fee Amount of $20.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $8.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $80.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX . Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Attorney Review Fee.  Fee Amount of $350.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Please provide E-sign consent agreement as the XXXXXX LE was e-signed.  Further testing will be ran for the 0% and 10% tolerance exceptions once the E-sign Consent Agreement is received

Reviewer Comment (2019-05-31): XXXXXX received E Consent dated XXXX . Exception Cleared. Buyer Comment (2019-05-31): Please see uploaded e-consent

03/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889289

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

RTC Due to same lender refi, form H-9 provided.

Reviewer Comment (2019-05-31): Borrower was provided a new 3 day rescission with the proper form. Condition cleared.

03/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.30710% or Final Disclosure APR of 9.36700% is in excess of allowable threshold of APOR 4.80% + 1.5%, or 6.30000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): XXXXXX mortgage purXXXXXXs HPML compliant loans.

03/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided the LO Compensation Disclosure at time of application.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

03/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $10,815.48 and disclosure timing violations.

Missing evidence of E-Sign Consent Disclosure. Initial LE dated XXXXXX was e-signed on XXXXXX.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared. Buyer Comment (2019-05-31): eConsent uploaded for review.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD did not reflect an amount by which the fees exceeded the legal limit.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Initial CD dated XXXXXX was not acknowledged as being received by the borrower a minimum of 3 business days prior to closing.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared. Buyer Comment (2019-05-31): CD tracking uploaded for review.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $310.00 exceeds tolerance of $0.00 plus 10% or $0.00.  Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance exceeded. Total amount of $310.00 exceeds tolerance of $0.00 plus 10% or $0.00. Insufficient or no cure was provided to the borrower. Initial LE dated XXXXXX reflects the fee, however, it was electronically signed and E-Signature Disclosure missing from the file.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $450.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXXXX reflects the fee, however, it was electronically signed and E-Signature Disclosure missing from the file.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXXXX reflects the fee, however, it was electronically signed and E-Signature Disclosure missing from the file.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Representative FICO score of ___ is less than Guideline representative FICO score of ___.

636 FICO less than minimum required per guidelines.  Approved Lender Exception in file.

Subject property is a new construction town home style condo Borrower has been XXXXXX for the past year and in the profession for 15 years. Borrower also consults for three other companies since XXXXXX LTV 80%, 5% < program maximum of 85% (with 640 credit score)

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

03/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Missing evidence borrower was provided a copy of the Anti Steering Disclosure at time of application.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

03/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD.

Borrower's final CD reflected seller fees in the amount of $8,339.60 yet Seller's final CD shows $86,247.09.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Commitment Fee.  Fee Amount of $XXXX exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXXXX reflects the fee, however, it was electronically signed and E-Signature Disclosure missing from the file.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for 3rd Quarter Taxes.  Fee Amount of $498.58 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXXXX reflects the fee, however, it was electronically signed and E-Signature Disclosure missing from the file.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for 3rd Quarter Taxes.  Fee Amount of $498.57 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXXXX reflects the fee, however, it was electronically signed and E-Signature Disclosure missing from the file.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for HOA Capital Contribution.  Fee Amount of $1,087.11 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Final CD reflected HOA Capital Contributions in section C vs. section H.

Reviewer Comment (2019-05-31): XXXXXX received Letter of Explanation, Proof of Delivery and Corrected CD.

03/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for HOA Dues.  Fee Amount of $198.55 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Final CD reflected HOA dues in section C vs. section H.

Reviewer Comment (2019-05-31): XXXXXX received Letter of Explanation, Proof of Delivery and Corrected CD.

03/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for HOA Maintenance Fee.  Fee Amount of $362.37 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Final CD reflected HOA Maintenance fees in section C vs. section H.

Reviewer Comment (2019-05-31): XXXXXX received Letter of Explanation, Proof of Delivery and Corrected CD.

03/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Attorney's Fee (Closing Agent And Other).  Fee Amount of $750.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE did not reflect an Attorney Review fee yet the final CD shows $750.00

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared.

03/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889301

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Project is new construction, first marketed in July XX. Allow pre-sale of 69.78% (xx units sold +xxx under contract (xxx) of xxx total units) vs program requirement that 70% of the units in the project must have been sold or under contract prior to the eighteenth month anniversary of the date in which the units in the project were first marketed. (Pre sale has reached 70.21%) Lender approved exception.

Reviewer Comment (2019-05-31): Since Pre sale has reached over 70% so the exception is now cleared. Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

03/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889305

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.96590% or Final Disclosure APR of 9.02500% is in excess of allowable threshold of APOR 4.12% + 1.5%, or 5.62000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-05-31): XXXXXX mortgage purXXXXXXs HPML compliant loans.

04/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889305

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charges under disclosed by -$540.77 - Lender did not include a Title - processing fee of $655.00 and Title - Services Sales Tax of $35.77.

Reviewer Comment (2019-05-31): XXXXXX received required documents, exception is cleared. Buyer Comment (2019-05-31): The XXXX  fee is a Title Departs / Search fee & the XXXX  Sales Tax of XXXX  are NON APR fees and are included in the 10% tolerance.  Please escalate.

04/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206889305

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Not provided

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

04/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889305

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 8.96590% or Final Disclosure APR of 9.02500% is in excess of allowable threshold of Prime Mortgage Market Rate 4.45000 + 1.75%, or 6.20000%.  Compliant SubPrime Loan.

Buyer Comment (2019-05-31): XXXXXX has elected to waive this exception.

04/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889305

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Representative FICO score of ___ is less than Guideline representative FICO score of ___.

Lender provided exception for credit score below 680

Borrower has been self-employed for the past 3 years as XXXXXX and has 10 years in the industry. DTI is 33.04372% < program max of 43.00%. Credit has been paid satisfactorily with 2 minor collections and no public records.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

04/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889305

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Aged document: Primary Valuation is older than guidelines permit

-

Appraisal effective date XXXXXX is greater than 120 days at close XXXXXX

Reviewer Comment (2019-05-31): 442 provided. Buyer Comment (2019-05-31): Re-Cert of valuation provided.

04/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206889308

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Lender approved exception for LTV exceeding program maximum.

Borrower has been self-employed for the past 20 years as an XXXXXX Perfect mortgage history paid as agreed since inception date of XXXXXX All unit owners are current on the homeowner association dues.  No pending litigation in the project.  Commercial space in the project is just 1.46% of the total square footage.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

04/22/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

B

B

A

A

N/A

N/A

No

206889308

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Lender approved exception for reserves months of 12 months not meeting the program minimum of 18 months.  However, calculated reserves months are 10.11 months.  Lender's approval conditioned for verification of cash out proceeds from refinance of another rental property.  Closing statement not provided.

Borrower has been self-employed for the past 20 years as an XXXXXX Perfect mortgage history paid as agreed since inception date of XXXXXX All unit owners are current on the homeowner association dues.  No pending litigation in the project.  Commercial space in the project is just 1.46% of the total square footage.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): Reserves are 10.27 vs program requirement of 12 months + 2 months for each additional investment properties owned (3 total properties = $37,219.48) Reviewer Comment (2019-05-31): Reserves  are 10.27 months < 18 months as required per guides. Reviewer Comment (2019-05-31): Closing statement was added to available assets, however still short reserves by $28,296.63. Buyer Comment (2019-05-31): Please advise if the previous closing statement that was uploaded clears the reserve requirement Reviewer Comment (2019-05-31): Per guide dated XXXXXX, if borrower owns inv properties other than the subject property, 2 months PITI for each inv property is required. Buyer Comment (2019-05-31): Per updated guidelines 12 months reserves required not 18. Please see attached  closing statement

04/24/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

B

B

A

A

N/A

N/A

No

206889308

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Lender's approval conditioned for verification of cash out proceeds from refinance of another rental property.  Closing statement not provided.

Reviewer Comment (2019-05-31): Corrected assets for cash to close.

04/23/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

B

B

A

A

N/A

N/A

No

206889308

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-05-31): XXXXXX has elected to waive

04/22/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

B

B

A

A

N/A

N/A

No

206889308

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception for use of financial information from Offering Plan vs. program requirement of budget.

Borrower has been self-employed for the past 20 years as an XXXXXX Perfect mortgage history paid as agreed since inception date of XXXXXX All unit owners are current on the homeowner association dues.  No pending litigation in the project.  Commercial space in the project is just 1.46% of the total square footage.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

04/22/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

B

B

A

A

N/A

N/A

No

206889308

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Qualifying interest rate discrepancy.

Using fully indexed rate 8.13638+.875 per guides for 9.01138 unable to determine Lenders qualifying rate of 8.757

Reviewer Comment (2019-05-31): Updated Qualifying interest rate to 8.757% per approval. Buyer Comment (2019-05-31): Qualifying Calculation uploaded for review.

04/23/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

B

B

A

A

N/A

N/A

No

206889308

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Guideline Requirement: Available for Reserves discrepancy.

Calculated Available for Reserves of ___ is less than Guideline Available for Reserves of ___.

Borrower has been self-employed for the past 20 years as an XXXXXX Perfect mortgage history paid as agreed since inception date of XXXXXX All unit owners are current on the homeowner association dues.  No pending litigation in the project.  Commercial space in the project is just 1.46% of the total square footage.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): Reserves are 10.27 vs program requirement of 12 months + 2 months for each additional investment properties owned (3 total properties = $37,219.48)

04/24/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

B

B

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

The subject LTV of 53.987% exceeds the program maximum allowable of 50%, however, a Lender Exception was granted to proceed at the higher LTV.

Perfect credit with no public records. Borrower has been an XXXXXX for the past 37 years. Multiple open and closed mortgages all paid as agreed since earliest inception XXXXXX. Credit score is 764, 84 points> program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): Client elects to waive with comp factors. An exception was also made by Client to use this income method as it is not the required Fannie Mae rental income calculation that was required on FNMA Form 1038. Utilizing the MGIC calculation does not hit the borrower up for the principal payment portion of over 50+ mortgages. Using the required FNMA method, the DTI ratio is 63.36978%. Using the MGIC method as exceptioned by the lender, the DTI ratio reduces to 43.521%. Buyer Comment (2019-05-31): Approved credit exception uploaded.

04/30/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

The subject loan amount exceeds the program maximum allowable of $5,000,000.00, however, a Lender Exception was granted to allow the loan to proceed.

Perfect credit with no public records. Borrower has been an XXXXXX for the past 37 years. Multiple open and closed mortgages all paid as agreed since earliest inception XXXXXX. Credit score is 764, 84 points> program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

04/29/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

The total debt ratio exceeds the program maximum allowable of 50% as well as it exceeds the debt to income ratio calculated at time of origination. The calculation of base income was significantly lower than the qualifying income figure at time of origination. Also, at time of origination there was a positive rental income cash-flow that the documents in file do not support. Instead, a negative rental figure has been calculated into the ratios. It also does not appear that the monthly mortgage payment of $xxx, belonging to the Borrower's primary residence, was not calculated into the ratios.

Perfect credit with no public records. Borrower has been an XXXXXX for the past 37 years. Multiple open and closed mortgages all paid as agreed since earliest inception XXXXXX. Credit score is 764, 84 points> program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): Client elects to waive with comp factors. An exception was also made by Client to use this income method as it is not the required Fannie Mae rental income calculation that was required on FNMA Form 1038. Utilizing the MGIC calculation does not hit the borrower up for the principal payment portion of over 50+ mortgages. Using the required FNMA method, the DTI ratio is 63.36978%. Using the MGIC method as exceptioned by the lender, the DTI ratio reduces to 43.521%. Buyer Comment (2019-05-31): This is based on the Traditional Method of Calculation, as per the exception. Reviewer Comment (2019-05-31): Sched E worksheet provided does not account for any current mtg payments (if any), taxes, ins and/or HOA fees. Provide updated worksheet with current PITI accounted for in calculation. Buyer Comment (2019-05-31): Exception and Rental Income Worksheet uploaded for review.

04/30/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

The Blanket Coverage for a Condo does not meet guidelines.

The Condo project blanket insurance policy is a Builder's Risk Policy versus the Fannie Mae requirement for a master policy that covers all units. A Lender Exception was granted to proceed with the Builder's Risk Policy.

Perfect credit with no public records. Borrower has been an XXXXXX for the past 37 years. Multiple open and closed mortgages all paid as agreed since earliest inception XXXXXX. Credit score is 764, 84 points> program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors. Buyer Comment (2019-05-31): The lender's exception was noted, why is this not being accepted and waived?

04/30/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

There was no documentation provided in file to confirm the monthly housing expense for each investment property. This includes insurance policies, tax certificates, HOA verification and in some cases mortgage statements.

Reviewer Comment (2019-05-31): Using schedule E income - using payment, taxes and insurance from tax returns. Buyer Comment (2019-05-31): Schedule E's were utilized in addition to REO docs both uploaded for review.

04/30/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

The appraisal report indicates that 108 of the 157 units are complete versus the program requirement that all units in the complex must be complete. A Lender Exception was granted to proceed.

Perfect credit with no public records. Borrower has been an XXXXXX for the past 37 years. Multiple open and closed mortgages all paid as agreed since earliest inception XXXXXX. Credit score is 764, 84 points> program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

04/29/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Loan Program requires that the homeowner's association's budget must include an allowance of capital reserves no less than 5% of the total expenditures included in such budget, however, the subject project budget only has 3.10% in capital reserves. A Lender Exception was granted to allow the loan to proceed.

Perfect credit with no public records. Borrower has been an XXXXXX for the past 37 years. Multiple open and closed mortgages all paid as agreed since earliest inception XXXXXX. Credit score is 764, 84 points> program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

04/29/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender Exception granted to allow use of the Mortgage Guaranty Insurance Traditional Method, using rows 1-3 and 7-9 only,  to calculate Schedule E income based off of 1 year tax return versus the 1038 method. - Per FNMA 1038 calculator mortgage interest paid, tax and HOA are to be included in calculation for ATR however these amounts were not per the exception.

Perfect credit with no public records. Borrower has been an XXXXXX for the past 37 years. Multiple open and closed mortgages all paid as agreed since earliest inception XXXXXX. Credit score is 764, 84 points> program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors. Buyer Comment (2019-05-31): Lender exception noted, why is this not downgraded and waived?

04/30/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Guideline Requirement: Available for Reserves discrepancy.

Calculated Available for Reserves of ___ is less than Guideline Available for Reserves of ___.

Lender approved exception - Reverses are 34.25 months + 110% of the loan amount vs program requirement for 110% of loan amount, plus 12 months reserves, plus 2 months additional PITIA in reserves for each additional mortgaged investment property.

Perfect credit with no public records. Borrower has been an XXXXXX for the past 37 years. Multiple open and closed mortgages all paid as agreed since earliest inception XXXXXX. Credit score is 764, 84 points> program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-05-31): XXXXXX has elected to waive this exception based on compensating factors.

04/29/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206889315

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Qualifying interest rate discrepancy.

Qualifying interest rate of ___ does not match Guideline qualifying interest rate of ___.

Per guides XXXX/18 base rate 9.24 (greater of the note or fully indexed rate) +1.9

Reviewer Comment (2019-05-31): Lender is utilizing a more conservative approach at 9.769% versus 8.13638%. Buyer Comment (2019-05-31): The +1.9 is from prior guidelines, Encompass is not calculating accordingly, see attached qualifying calculation worksheet.

04/30/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

206918662

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Application / Processing

Missing Document: Missing Lender's Initial 1003

Missing lenders 1003 used an alternate source to establish application date

Buyer Comment (2019-06-03): The initial 1003 was taken over the phone and we don't require the borrower to sign it - they sign the final Reviewer Comment (2019-06-03): Rec'd an unsigned 1003.

01/02/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

A

B

B

A

A

N/A

N/A

No

206918662

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The subject property is located in a FEMA disaster that does not have a declared end date.

No damage at time of appraisal but fires are currently in area

Reviewer Comment (2019-06-03): Rec'd PDI dated XXXX  No damage.

12/07/2018

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

A

B

B

A

A

N/A

N/A

No

206918662

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

FNMA Points and Fees

FNMA Points and Fees on subject loan of 5.46968% is in excess of the allowable maximum of the greater of 5.00000% of the Original Loan Amount and $1000.00 (2018). FNMA Finance Charge total $XXXXX on a Original Loan Amount of $XXXXXX vs. an allowable total of $XXXXX and $1000.00 (2018) (an overage of $XXXX or .46968%).

Lenders test shows a high cost loan

Buyer Comment (2019-06-03): Loan is Non-QM

12/06/2018

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

A

B

B

A

A

N/A

N/A

Yes

206918662

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Aged document: Asset Account date is more than 90 days prior to the note.

Financial Institution: XXXXXX / End Date: XXXXXX // Account Type: XXXXXX / Account Number: XXXXXX Asset Account Date: ___

An aged 401k statement was used a more recent one should have been provided

Reviewer Comment (2019-06-03): Funds not needed. Buyer Comment (2019-06-03): This account is not needed for reserves so we can back out the balance of XXXX

12/07/2018

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

A

B

B

A

A

N/A

N/A

No

206918662

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

PDI provided is dated XXXXXX which was before the end date of the FEMA disaster.

Reviewer Comment (2019-06-03): Rec'd PDI, no damage noted.

05/24/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

A

B

B

A

A

N/A

N/A

No

206918680

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Lender's approval not provided.

Reviewer Comment (2019-06-03): Document provided

03/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

206918680

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Disclosure not provided.

Reviewer Comment (2019-06-03): Attestation approved by XXXXXX in file.

01/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

206918680

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation. (XXXXXX)

The Final CD provided on XXXXXX disclosed a Closing Date of XXXXXX instead of the actual date of consummation XXXXXX.

Reviewer Comment (2019-06-03): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

206918680

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure XXXXXX 12:00:00 AM was received. (XXXXXX)

The revised LE issued XXXXXX was received on XXXXXX which was after the initial CD was issued on XXXXXX.

Reviewer Comment (2019-06-03): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

206918680

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXXX not received by borrower at least four (4) business days prior to closing. (XXXXXX)

The revised LE issued XXXXXX was received by the Borrower on XXXXXX which was less than the required 4 business days prior to closing on XXXXXX.

Reviewer Comment (2019-06-03): mailbox rule applied exception cleared

05/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

206918680

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Missing secondary valuation product required for securitization.

Reviewer Comment (2019-06-03): document provided

03/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

206918680

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (XXXXXX)

The final CD discloses the loan is not assumable, the note contains assumption language.

Reviewer Comment (2019-06-03): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

206918708

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-06-03): Approval provided.

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

More than 3 NSFs/Overdraft Transfers occurred in the most recent 12-month period.

Borrower has excessive NSF's on business and on personal bank accounts.  LOX does not explain why they are so excessive.  Guidelines state reasonable within the last 12 months. 104 is not reasonable.

Borrower has a disposable income of $8,700 75% LTV < 85% guideline max.

Originator Originator

Reviewer Comment (2019-06-03): Rec'd exception for excessive NSF activity. Reviewer Comment (2019-06-03): The LOE is not sufficient for the amount of NSF's that have occurred.  Guidelines state "reasonable" to which 104 does not appear to be reasonable.  Lender to provide further support for approval of bank statement loan with excessive number of NSF's. Buyer Comment (2019-06-03): this LOE explains the situations around the overdrafts and nsf's

05/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2019-06-03): Sufficient coverage provided. Buyer Comment (2019-06-03): the coverage is acceptable as it shows 100% replacement costs and XXXX  increased dwelling

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

XXXXXX is disbursement date.

Reviewer Comment (2019-06-03): Rec'd revised hazard policy reflecting XXXX effective date. Buyer Comment (2019-06-03): final eoi attached Buyer Comment (2019-06-03): disbursement date is XXXX Reviewer Comment (2019-06-03): Per the final CD and closing statement in file, the loan disbursed XXXX

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-06-03): Rec'd fraud report.

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Credit Report: Original // Borrower: XXXXXX

Reviewer Comment (2019-06-03): Rec'd fraud report.

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Loan Designation set per Deal instructions.

Reviewer Comment (2019-06-03): Rec'd exception for DTI > 50%. Reviewer Comment (2019-06-03): Rec'd income worksheet already in file.  Per guidelines, the income used to qualify is to be the lower of the P&L Statement average or the amount stated on the initial signed 1003. Unable to determine how lender derived calculation of XXXX  but the lowest amount is XXXX per initial signed 1003. Additionally, debts were marked as paid by business, but the payments do not show consistently on the business bank statements. Using the lower income and including all payments brings the DTI to XXXX  which is out of tolerance.

05/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918708

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 56.00470% significantly exceeds the guideline maximum of 50.00%.  (DTI Exception cannot be compensated to a lower grade.)

Per guidelines, the income used to qualify is to be the lower of the P&L Statement average or the amount stated on the initial signed 1003.  Unable to determine  how lender derived calculation of $24,799.56, but the lowest amount is $20,000 per initial signed 1003.  Additionally,  debts were marked as paid by business, but the payments do not show consistently on the business bank statements.  Using the lower income and including all payments brings the DTI to 56.0047% which is out of tolerance.

Borrower has a disposable income of $8,700 75% LTV < 85% guideline max.

Originator Originator

Reviewer Comment (2019-06-03): Please note the original exception verbiage is no longer accurate, the DTI is XXXX and guidelines allow 50% Reviewer Comment (2019-06-03): Rec'd exception for DTI > 50%. Reviewer Comment (2019-06-03): Rec'd income worksheet already in file.  Per guidelines, the income used to qualify is to be the lower of the P&L Statement average or the amount stated on the initial signed 1003. Unable to determine how lender derived calculation of XXXX , but the lowest amount is XXXX per initial signed 1003. Additionally, debts were marked as paid by business, but the payments do not show consistently on the business bank statements. Using the lower income and including all payments brings the DTI to XXXX which is out of tolerance.

05/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (XXXXXX)

Assumption language on the note.

Buyer Comment (2019-06-03): This was a system glitch and has now been fixed

04/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918708

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Initial 1003 states $20000 a month in income.  Final 1003 states $25000 a month in income.  P&L shows a negative for income.

Borrower has a disposable income of $8,700 75% LTV < 85% guideline max.

Originator Originator

Reviewer Comment (2019-06-03): Please note the original exception verbiage is no longer accurate, the DTI is XXXX  and guidelines allow 50% Reviewer Comment (2019-06-03): Rec'd exception for DTI > 50%. Buyer Comment (2019-06-03): Underwriter used XXXX  income and XXXX  Asset Depletion XXXX  Also XXXX  and 1 of the XXXX  accounts is consistently paid by the business all others have been added back to the DTI, see exception for DTI over 50%. Reviewer Comment (2019-06-03): Rec'd income worksheet already in file.  Per guidelines, the income used to qualify is to be the lower of the P&L Statement average or the amount stated on the initial signed 1003. Unable to determine how lender derived calculation of XXXX  but the lowest amount is XXXX per initial signed 1003. Additionally, debts were marked as paid by business, but the payments do not show consistently on the business bank statements. Using the lower income and including all payments brings the DTI to XXXX which is out of tolerance.

05/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

ATR fail due to excessive DTI

Reviewer Comment (2019-06-03): Rec'd exception for DTI > 50%. Reviewer Comment (2019-06-03): Rec'd income worksheet already in file.  Per guidelines, the income used to qualify is to be the lower of the P&L Statement average or the amount stated on the initial signed 1003. Unable to determine how lender derived calculation of XXXX  but the lowest amount is XXXX  per initial signed 1003. Additionally, debts were marked as paid by business, but the payments do not show consistently on the business bank statements. Using the lower income and including all payments brings the DTI to XXXX  which is out of tolerance. Buyer Comment (2019-06-03): income worksheet attached

05/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918708

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 53.80365% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower has a disposable income of $8,700 75% LTV < 85% guideline max.

Originator Originator

Reviewer Comment (2019-06-03): Rec'd exception for DTI > 50%.

05/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918715

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Title Error: Title vesting does not concur with deed

Reviewer Comment (2019-06-03): Rec'd final title.  Vesting is consistent. Buyer Comment (2019-06-03): title policy attached

05/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918715

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Reviewer Comment (2019-06-03): Rec'd final title.

05/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918715

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

DTI is higher due to the Lender using a higher income than that verified by audit.

Borrower has a disposable income of $5,600 10 months reserves.

Originator Originator

Reviewer Comment (2019-06-03): Rec'd exception for DTI > 50%. Buyer Comment (2019-06-03): exception approval attached

05/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918715

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Closing costs overage was not disclosed.

Reviewer Comment (2019-06-03): XXXXXX reviewed exception. Fee is paid to same provider. Exception Cleared. Buyer Comment (2019-06-03): coc at docs attached

05/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918715

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX SB 1894

XXXXXX Predatory Lending Database Program (SB 1894) - Certificate of Compliance or Exemption not attached to mortgage for recording.

Certificate of Compliance not found in the file.

Reviewer Comment (2019-06-03): Rec'd Certificate.

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918715

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - State of II Policy Registration Fee.  Fee Amount of $3.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (7712)

Initial LE disclosed $3.00 fee as Archiving Fee (Warehouse). Not consistent with fee description on final CD.

Reviewer Comment (2019-06-03): XXXXXX reviewed exception. Fee is paid to same provider. Exception Cleared.

05/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918715

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation. (XXXXXX)

The final Closing Disclosure reflects a Closing Date of XXXXXX, but the transaction consummation (mortgage notary) date was XXXXXX.

Reviewer Comment (2019-06-19): Client elects to Waive Reviewer Comment (2019-06-03): XXXXXX received PCCD correcting close date and LOE however the 60 day window has passed from the date of discovery. Unable to Cure. Reviewer Comment (2019-06-03): XXXXXX received final settlement statement indicating consummation of XXXX  supporting the close date is XXXX . Please provide corrected CD and LOE to cure. Buyer Comment (2019-06-03): master settlement statement showing XXXX  closing Reviewer Comment (2019-06-03): XXXXXX received the Final CD. The close date indicates XXXX however the date of consummation per security instrument is XXXX . Please provide corrected CD and LOE to cure.

06/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918715

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 51.65585% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Compensation factors were not provided for DTI increase. Lender calculation of self employed income is higher than audit.

Borrower has a disposable income of $5,600 10 months reserves.

Originator Originator

Reviewer Comment (2019-06-03): Rec'd exception for DTI > 50%.

05/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918715

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Reviewer Comment (2019-06-03): Rec'd exception for DTI

05/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918715

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to DTI over guidelines.

Reviewer Comment (2019-06-03): Rec'd exception for DTI

05/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918715

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (XXXXXX)

Note states assumable, CD is correct. Guidelines do not allow assumable.

Reviewer Comment (2019-06-03): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918739

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Verified reserves after closing of $24,407.22 are insufficient to cover 6 months of reserves of $26,753.64 (subject PITI of $4,458.94 x 6 months) as required by XXXXXX Bank Statement Guidelines.

Borrower on this Bank Statement documentation loan has a disposable income of $9,093.73

Originator

Reviewer Comment (2019-06-03): Lender approved exception for the reserve shortage with 1 verified compensating factor.

05/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

206918739

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Missing Document: Credit Letter of Explanation (LOE) not provided

Borrower filed Chapter 13 Bankruptcy that was dismissed on XXXXXX. File is missing the borrower's letter of explanation as required by XXXXXX Underwriting Guidelines.

Borrower on this Bank Statement documentation loan has a disposable income of $9,093.73

Originator

Reviewer Comment (2019-06-03): Rec'd exception for missing bankruptcy LOE. Buyer Comment (2019-06-03): LOE not required when it is that old.

05/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

206918739

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Guideline Issue:  Insufficient tradelines per credit guidelines

Credit Report verifies 1 open mortgage and 1 authorized user credit card tradeline. XXXXXX Underwriting Guidelines require at least 4 major tradelines and authorized user accounts cannot be used to verify the borrower's credit history. No other open and active accounts were reported, no alternative credit documentation was provided, and file is missing a lender exception to allow the borrower's insufficient credit history.

Borrower on this Bank Statement documentation loan has a disposable income of $9,093.73

Originator

Reviewer Comment (2019-06-03): Lender approved exception for insufficient tradelines with 1 verified compensating factor.

05/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

206918739

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-06-03): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

206918744

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Missing income/employment documentation.

Reviewer Comment (2019-06-03): Underlying doc exceptions have been cleared, diligence designation is Non-QM Reviewer Comment (2019-06-03): Ok to waive per client.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918744

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - Bank Statements

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current employment status using reasonably reliable third-party records.

CPA letter not provided for reliable 3rd party verification of self-employment.

Reviewer Comment (2019-06-03): Rec'd printout dated 1/XX19.

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918744

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Missing income/employment information.

Reviewer Comment (2019-06-03): Rec'd printout dated 1/XX19.

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918744

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

Amount shown on initial escrow disclosure is $4323.71 while the CD amount is $4370.13.

Reviewer Comment (2019-06-03): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918744

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller closing disclosure not located.

Reviewer Comment (2019-06-03): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

206918744

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Waiver Less than 3 Days From Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Borrower provided appraisal waiver less than three (3) business days prior to consummation.

Signed waiver in file is dated the same as the closing date.

Reviewer Comment (2019-06-03): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918744

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Representative FICO score of ___ is less than Guideline representative FICO score of ___.

Per guidelines, it appears the minimum credit score is 680 and borrowers do not appear to meet this requirement.

0 X 30 over 30 months housing history vs guideline minimum of 0 x 30 over 12 months Borrower on this Bank Statement documentation loan has a disposable income of $9,670.34

Originator Originator

Reviewer Comment (2019-06-03): Lender approved exception for the qualifying FICO of 677 is less than the guideline minimum of 680.

05/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206918744

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Per guidelines, 6 months reserves are required and borrowers do not have enough funds verified in file to meet this requirement.

0 X 30 over 30 months housing history vs guideline minimum of 0 x 30 over 12 months Borrower on this Bank Statement documentation loan has a disposable income of $9,670.34

Originator Originator

Reviewer Comment (2019-06-03): Lender approved exception for the reserves of 4.04 are less than Guideline PITIA months reserves of 6.00.

05/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

206945278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-06-07): XXXXXX has elected to waive this exception.

05/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206945278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.35730% or Final Disclosure APR of 8.38200% is in excess of allowable threshold of APOR 4.61% + 2.5%, or 7.11000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-06-07): XXXXXX mortgage purXXXXXXs HPML compliant loans.

05/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206945278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-06-07): XXXXXX has elected to waived this exception.

05/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206945278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

The initial CD was provided on XXXXXX with no evidence of early receipt; the borrower signed on XXXXXX.

Reviewer Comment (2019-06-07): Evidence of earlier receipt provided to XXXXXX Buyer Comment (2019-06-07): please see ESIGN, CD TRACKING

05/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206945278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure XXXXXX 12:00:00 AM was received.

LE issued on 0XXXXXX received by the borrower on 0XXXXXX (confirmed from E-signed LE) which is the same day the Initial CD was issued and received by the borrower.

Buyer Comment (2019-06-07): XXXXXX has elected to waive this exception

05/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Application / Processing

Missing Document: Missing Lender's Initial 1003

Lenders initial 1003 was not provided.

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Lenders loan approval was not provided with loan documents.

Reviewer Comment (2019-06-07): Approval has been provided.

05/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX ___

XX W2 was not provided.

Reviewer Comment (2019-06-13): Cleared Buyer Comment (2019-06-07): the borrower works in XXXXXX they dont issue US W2's Buyer Comment (2019-06-07): The borrower works in XXXXXX - they are not a part of the US and dont issue W2's

06/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.40200% or Final Disclosure APR of 6.47700% is in excess of allowable threshold of APOR 4.71% + 1.5%, or 6.21000%.  Non-Compliant Higher Priced Mortgage Loan.

No high cost documents were found in loan package or high cost tests

Reviewer Comment (2019-07-09): Evidence received second appraisal not paid by borrower. Loan is HPML Compliant. Reviewer Comment (2019-06-13): Re-opening exception, EV3/C, waiving doesn't improve loan grade. Must revisit the exception. Buyer Comment (2019-06-07): we know the loan is HPML

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals.

2 appraisals were performed and for by borrower

Reviewer Comment (2019-07-09): Invoice received showing second appraisal was not paid by borrower. Exception cleared. Reviewer Comment (2019-06-13): Re-opening exception, EV3/C, waiving doesn't improve loan grade. Must revisit the exception. Buyer Comment (2019-06-07): the borrower did not pay for the second appraisal.  it was paid on his behalf outside of closing Reviewer Comment (2019-06-07): Unable to verify who payee is with invoice provided, please provide clarification along with a corrected CD, letter of explanation and proof of delivery to cure this exception. Buyer Comment (2019-06-07): The borrower did not pay for the 2nd appraisal, it was paid outside of closing on his behalf - see attached

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property.  (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter)

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

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

Rate agreements were not found in file

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

The broker fee agreement was not found in file

Reviewer Comment (2019-06-07): Attestation approved by AMC in file.

01/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Closing disclosure indicates assumption will not be allowed.

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Borrower Paid - At Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  XXXXXX disclosed Total Closing Costs (Paid by Borrower at Closing) that does not match sum of fees. (Final/ XXXXXX)

Fees match provided closing disclosure.

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Borrower Paid - Before Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  XXXXXX disclosed Total Closing Costs (Paid by Borrower Before Closing) that does not match sum of fees. (Final/ XXXXXX)

Fees match provided closing disclosure.

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation. (XXXXXX)

Fees match provided closing disclosure.

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

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

Home loan toolkit does not have a date.

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees seller paid fees do not match Consumer's Final CD

TILA-RESPA Integrated Disclosure: the Seller's final CD total seller paid fee amounts do not match the values used for compliance testing. (Final/XXXXXX)

Fees match provided closing disclosure.

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

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

Settlment service provider did not indicates services.

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA NMLSR - Originator Company Not Licensed at time of Application

Unable to test LO company NMLS license due to missing information.

Initial 1003 and alternate credit source were not located in the loan package

Reviewer Comment (2019-06-07): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal Loan Originator Compensation - Individual LO Not NMLS Licensed at Time of Application

Unable to test Loan Originator license due to missing information.

Initial 1003 and alternate credit source were not located in the loan package

Reviewer Comment (2019-06-07): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA NMLSR - Individual Originator License Status Not Approved

Unable to test Individual Loan Originator license status due to missing information.

Initial 1003 and alternate credit source were not located in the loan package

Reviewer Comment (2019-06-07): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA NMLSR - Originator Company License Status Not Approved

Unable to test LO company status due to missing information.

Initial 1003 and alternate credit source were not located in the loan package

Reviewer Comment (2019-06-07): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.

Initial 1003 and alternate credit source were not located in the loan package

Reviewer Comment (2019-06-07): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.

Initial 1003 and alternate credit source were not located in the loan package

Reviewer Comment (2019-06-07): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.

Initial 1003 and alternate credit source were not located in the loan package

Reviewer Comment (2019-06-07): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

AUS Findings: All conditions were not met

Lender required prior year W2 for income, this was not provided

Reviewer Comment (2019-06-07): Not AUS loan.  Client waived XX W-2 requirement.

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Paid Loan Costs Total Section B

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX disclosed Total Services Borrower Did Not Shop For (Section B) that does not match sum of fees.

.

Reviewer Comment (2019-07-09): Waived at client request, EV2.

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206945951

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Paid By Others

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  XXXXXX disclosed Total Closing Costs (Paid by Others) that does not match sum of fees.

.

Reviewer Comment (2019-07-09): Waived at client request, EV2.

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206952469

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

- ___

Verification of monthly payment not provided.

Reviewer Comment (2019-07-11): Received the mortgage statements which include escrows.

07/11/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206952469

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-07-11): Received the final commitment letter.

07/11/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Reviewer Comment (2019-07-11): Received the List of Homeownership Counseling Organizations provided at application.

07/11/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-06-19): Letter of Explanation & Corrected Closing Disclosure provided

06/19/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

Final CD disclosed TIP of 123.811%, however,  the actual total interest percentage for the loan is 123.463%.

Reviewer Comment (2019-06-19): Letter of Explanation & Corrected Closing Disclosure provided

06/19/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $241.70 exceeds tolerance of $214.00 plus 10% or $235.40.  Sufficient or excess cure was provided to the borrower at Closing.

Binding LE disclosed Recording Fee of $214 subject to 10% tolerance or $235.40 and Final CD disclosed $241.70.  Final CD disclosed a Lender Credit of $6.30 for increase in Closing Costs above the legal limit which is sufficient to cure 10% tolerance violation.

06/14/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - C Corporation 1120

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

File contains the borrowers XX and XX XXXXXX tax returns along with a XX P&L statement and XX Balance Sheet. P&L's and  Balance Sheets were not provided for XX and XXXXXX YTD through XXXXXX. In addition, the business entity filing provided in the file does not verify the business incorporation date to verify at least 2 years of self-employment.

Reviewer Comment (2019-10-29): Upon further review, this exception has been cleared. Foreign National borrowers incomes were verified in accordance with Pacor Foreign National guidelines. Reviewer Comment (2019-10-29): Revised. Reviewer Comment (2019-07-11): Upon further research, exception has been cancelled.

10/29/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - C Corporation 1120

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

File contains the borrowers XX and XX XXXXXX  returns along with a XX P&L statement and XX Balance Sheet. P&L's and  Balance Sheets were not provided for XX and XXXXXX  YTD through XXXXXX. In addition, the business entity filing provided in the file does not verify the business incorporation date to verify at least 2 years of self-employment.

Reviewer Comment (2019-10-29): Upon further review, this exception has been cleared. Foreign National borrowers incomes were verified in accordance with Pacor Foreign National guidelines. Reviewer Comment (2019-10-29): Revised. Reviewer Comment (2019-07-11): Upon further research, exception has been cancelled.

10/29/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines Not Provided

Ability to Repay (Dodd-Frank 2014): Unable to determine ability to repay due to missing guidelines. Loan characteristics are DTI: XX%, LTV/CLTV: XX%/XX%, Credit Score: XXX, Occupancy: XXXXXX, Purpose: Refinance, Cash-out - Other

Calculated income is less than verified by lender.

Reviewer Comment (2019-10-29): Upon further review, this exception has been cleared.  XXXXXX Foreign National guidelines have been provided. Reviewer Comment (2019-10-29): Exception should be cancelled, not overridden. Reviewer Comment (2019-06-17): Guidelines have been provided.

10/29/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

General Ability to Repay requirements not met due to missing self-employment income documentation.

Reviewer Comment (2019-10-29): Upon further review, this exception has been cleared. Foreign National borrowers incomes were verified in accordance with Pacor Foreign National guidelines. Reviewer Comment (2019-10-29): Revised. Reviewer Comment (2019-07-11): Upon further research, exception has been cancelled.

10/29/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Due to missing self-employment income documentation, the subject loan designation is ATR Fail.

Reviewer Comment (2019-10-29): Upon further review, this exception has been cleared. Foreign National borrowers incomes were verified in accordance with Pacor Foreign National guidelines. Reviewer Comment (2019-10-29): Revised. Reviewer Comment (2019-07-11): Upon further research, exception has been cancelled.

10/29/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

File is missing evidence the borrowers were provided and received a copy of the second appraisal at least 3 business days prior to closing.

Reviewer Comment (2019-07-11): Upon further research, exception has been cancelled.

07/11/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206952469

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

File is missing evidence the borrowers were provided and received a copy of the first appraisal at least 3 business days prior to closing.

Reviewer Comment (2019-07-11): Received verification the initial appraisal was delivered to the borrowers on XXXXXX.

07/11/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit disclosure not provided to the Borrower

Reviewer Comment (2019-06-14): Disclosure Tracking provided. Buyer Comment (2019-06-14): See Disclosure tracking provided

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

The CD was provided at closing.

Reviewer Comment (2019-06-14): XXXXXX received XX26 CD. Exception Cleared Buyer Comment (2019-06-14): Initial CD provided

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $7,978.90 may be required.

Loan Estimate not in file.

Reviewer Comment (2019-06-14): XXXXXX received XX6 and 4/24 LEs. Exception Cleared. Buyer Comment (2019-06-14): LE's provided

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Reviewer Comment (2019-06-14): Disclosure Tracking provided. Buyer Comment (2019-06-14): ARM Disclosure provided

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Reviewer Comment (2019-06-14): Disclosure Tracking provided. Buyer Comment (2019-06-14): Disclosure Tracking also provided Buyer Comment (2019-06-14): CHARM booklet provided

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-06-14): Receipt of Appraisal provided. Reviewer Comment (2019-06-14): Exceptions is in regards to document signed at closing confirming borrower receipt of appraisal.

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-06-14): XXXXXX received XX6 and 4/24 LEs. Exception Cleared. Buyer Comment (2019-06-14): See Disclosure Tracking provided.

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-06-14): Receipt of Appraisal provided. Reviewer Comment (2019-06-14): Exceptions is in regards to document signed at closing confirming borrower receipt of appraisal. Buyer Comment (2019-06-14): Evidence borrower received valuation within allowed time frame provided. Please clear.

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-06-14): XXXXXX received XX6 and 4/24 LEs. Exception Cleared.

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Reviewer Comment (2019-06-14): Disclosure Tracking provided. Buyer Comment (2019-06-14): See Disclosure Tracking provided.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower.

Reviewer Comment (2019-06-14): XXXXXX Subprime Counseling Disclosure provided Buyer Comment (2019-06-14): Disclosure provided

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided)

XXXXXX Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan.

Reviewer Comment (2019-06-14): LE provided reflects Taxes and Insurance Buyer Comment (2019-06-14): LE provided reflects Taxes and Insurance - please clear

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.92220% or Final Disclosure APR of 8.03900% is in excess of allowable threshold of APOR 4.69% + 1.5%, or 6.19000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-06-14): Receipt of Appraisal provided.

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.92220% is in excess of allowable threshold of Prime Mortgage Market Rate 3.84000% + 1.75%, or 5.59000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-06-25): XXXXXX Subprime Counseling Disclosure provided Buyer Comment (2019-06-14): See trailing document Reviewer Comment (2019-06-14): XXXXXX Subprime Counseling Disclosure provided

06/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

The loan is at ATR risk due to the DTI exceeding the program maximum.

Reviewer Comment (2019-06-14): Agree with lender. Per Article V of divorce decree, child support is $500.00 per month.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 44.18672% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Lender exception not provided for the DTI.  Lender's calculated DTI is 38.738.

Reviewer Comment (2019-06-14): Agree with lender. Per Article V of divorce decree, child support is $500.00 per month.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-06-14): XXXXXX received XX6 and 4/24 LEs. Exception Cleared. Buyer Comment (2019-06-14): See Disclosure Tracking provided.

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206964274

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Per lender's approval, DTI is 38.738%.  Calculated DTI with debts on credit report of $1,421 and child support of $1,000 (per addendum) is 44.187%.  Calculated total debt of $2,421 matches the final 1003.  Unable to determine how lender's DTI of 38.738% was calculated.

Reviewer Comment (2019-06-14): Agree with lender. Per Article V of divorce decree, child support is $500.00 per month. Buyer Comment (2019-06-14): Divorce Decree Amendment dated XXXX reflects adjusted child support of $500 monthly.  Please clear.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

The loan is at ATR risk due to the DTI exceeding the program maximum.

Reviewer Comment (2019-06-14): Agree with lender. Per Article V of divorce decree, child support is $500.00 per month.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing the ComplianceEase or Mavent as required per the guides.

Reviewer Comment (2019-06-14): Mavent provided Buyer Comment (2019-06-14): Mavent provided

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

XXXXXX received XXXXXX and XXXXXX LEs. The Loan Origination Fee increased without a valid change of circumstance on the XX24 LE. Please provide COC if available or corrected CD, LOE, Refund Check, and Proof of Delivery to cure.

Buyer Comment (2019-06-14): XXXXXX has elected to waive this exception.

05/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206964274

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Origination Fee.  Fee Amount of $1,526.40 exceeds tolerance of $1,483.00.  Insufficient or no cure was provided to the borrower.

XXXXXX received XXXXXX and XXXXXX LEs. The Loan Origination Fee increased without a valid change of circumstance on the XX24 LE. Please provide COC if available or corrected CD, LOE, Refund Check, and Proof of Delivery to cure.

Reviewer Comment (2019-06-14): XXXXXX received XX24 COC. Exception Cleared. Buyer Comment (2019-06-14): See VCC provided

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206964274

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.92220% is in excess of allowable threshold of Prime Mortgage Market Rate 3.77000% + 1.75%, or 5.52000%.  Compliant SubPrime Loan.

Buyer Comment (2019-06-14): XXXXXX has elected to waive this exception.

06/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964302

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing all bank statements used for income analysis, account xxxxxx.

Reviewer Comment (2019-06-14): Bank statements for account XXXXXXprovided.

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

No

206964302

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Approved lender exception doc 207 for DTI exceeding program max of 50% at 57.373% please provide a revised exception as review DTI is 63.35868%.

No derogatory credit and no public records. Borrower self-employed  investor for 20 years. 51 months reserves vs. program required 16 months. 760 credit score vs. program min. of 720.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-14): DTI is 57.373% vs program max of 50% Buyer Comment (2019-06-14): Please see uploaded statements and giving them credit for the $ 9,119.16 per month for 4.6% Interest income on remainder of assets after close?  Which is on the approved exception

06/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

No

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

ATR risk due to DTI exceeding program max of 50% at 57.373% please provide a revised exception as review DTI is 63.35868%..

Reviewer Comment (2019-06-14): DTI is 57.373% vs program max of 50% Buyer Comment (2019-06-14): Please see uploaded statements and giving them credit for the $ 9,119.16 per month for 4.6% Interest income on remainder of assets after close?  Which is on the approved exception

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

No

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs don't match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTIs calculated in accordance with the Lenders Guidelines of 63.35868% and based on 1026.43(c)(5) of 64.29% significantly exceed the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

ATR risk due to DTI exceeding program max of 50%at 57.373% please provide a revised exception as review DTI is 63.35868%.

No derogatory credit and no public records. Borrower self-employed  investor for 20 years. 51 months reserves vs. program required 16 months. 760 credit score vs. program min. of 720.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-14): DTI is 57.373% vs program max of 50% Buyer Comment (2019-06-14): Please see uploaded statements and giving them credit for the $ 9,119.16 per month for 4.6% Interest income on remainder of assets after close?  Which is on the approved exception

06/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

No

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Courier / Express Mail / Messenger Fee.  Fee Amount of $150.00 exceeds tolerance of $75.00.  Insufficient or no cure was provided to the borrower.

No cure provided for overage, courier fee increased without VCC.

Reviewer Comment (2019-06-14): See newly added exception. Borrower shopped for service provider not on SSPL. Buyer Comment (2019-06-14): Not required - no limit - borrower  can shop for NO VCC required

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

ATR Risk

Yes

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Loan Tie-In Fee.  Fee Amount of $250.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided for overage, loan tie-in fee added without VCC.

Reviewer Comment (2019-06-14): See newly added exception. Refund provided.

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

ATR Risk

Yes

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $15.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided for overage, recording service fee added without VCC.

Reviewer Comment (2019-06-14): See newly added exception. Refund provided.

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

ATR Risk

Yes

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Qual Method differs from ATR result is Understated DTI

Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender does not adhere with ATR payment calculation methods under 1026.43(c)(5), the method rendered a DTI less than that prescribed under ATR.

Custom XXXXXX I/O qualifying method.

Buyer Comment (2019-06-14): XXXXXX has elected to waive Reviewer Comment (2019-06-14): Unable to clear EV-2 exceptions. Buyer Comment (2019-06-14): This is a 40 year term

06/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

No

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Property Taxes Escrow

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed property taxes figures under Initial Escrow Payment at Closing that does not match amount per month calculation.

Final CD shows monthly RE taxes as $10,833.00/mo. in Section G, however verified RE taxes are $10,833.3XXmo.

Reviewer Comment (2019-06-14): calculation correct -estimated escrow is correct 10833.33+937.08=11770.41 Tax Figure was truncated due to length of characters. Buyer Comment (2019-06-14): See calculation on CD 6 x10.833.33=64999.98- calculation correct -estimated escrow is correct 10833.33+937.08=11770.41 Figure was truncated

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

ATR Risk

Yes

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Not provided, field not shown on CD.  No cure provided for overages.

Reviewer Comment (2019-06-14): Letter of Explanation & Corrected Closing Disclosure provided.

06/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

ATR Risk

Yes

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

ATR risk due to DTI exceeding program max of 50% Lender exception at 57.373% please provide a revised exception as review DTI is 63.35868%..

Reviewer Comment (2019-06-14): Added asset depletion income to qualifying income. Buyer Comment (2019-06-14): Please see uploaded statements and giving them credit for the $ 9,119.16 per month for 4.6% Interest income on remainder of assets after close?  Which is on the approved exception

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

ATR Risk

Yes

206964302

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow use of 100% of rental income from commercial investment properties and not obligate borrower for T&I.

No derogatory credit and no public records. Borrower self-employed  investor for 20 years. 51 months reserves vs. program required 16 months. 760 credit score vs. program min. of 720.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-14): XXXXXX mortgage has elected to waive this exception based on compensating factors.

06/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

No

206964302

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Approved lender exception doc 207 to allow primary residence to close in an LLC (XXXXXX

No derogatory credit and no public records. Borrower self-employed  investor for 20 years. 51 months reserves vs. program required 16 months. 760 credit score vs. program min. of 720.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-14): XXXXXX mortgage has elected to waive this exception based on compensating factors.

06/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

No

206964302

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow assumption of 4.6% interest on post closing liquid assets.

No derogatory credit and no public records. Borrower self-employed  investor for 20 years. 51 months reserves vs. program required 16 months. 760 credit score vs. program min. of 720.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-14): XXXXXX mortgage has elected to waive this exception based on compensating factors.

06/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

No

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Loan Tie-In Fee.  Fee Amount of $250.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

AMC received PCCD and LOE for tolerance cure.  Need copy of refund check to cure.

Reviewer Comment (2019-06-14): AMC received the PCCD, LOE and refund check.

06/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

Yes

206964302

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $15.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

AMC received PCCD and LOE for tolerance cure.  Need copy of refund check to cure.

Reviewer Comment (2019-06-14): AMC received the PCCD, LOE and refund check.

06/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

ATR Risk

Yes

206964303

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-06-14): XXXXXX has elected to waive this exception.

06/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964303

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Total Closing Costs exceeded the legal limit.

Reviewer Comment (2019-06-14): VCC provided. Buyer Comment (2019-06-14): Please see COC 4-1 and COC 5-20

06/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206964303

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure XXXXXX 12:00:00 AM was received.

The Loan Estimate issued XXXXXX was not signed by the Borrower. The estimated date of receipt of XXXXXX is after the date the initial CD was issued.

Buyer Comment (2019-06-14): XXXXXX has elected to waive this exception. Reviewer Comment (2019-06-14): Since LE was not signed it cannot be determined if when the Borrower received the revised LE and have sufficient time to review prior to issuance of the initial closing disclosure.  The mailbox rule was applied.  Please provide evidence of earlier receipt to clear. Buyer Comment (2019-06-14): The compliance regulation indicates you cannot send an LE and CD on the same day, it says nothing about receipt prohibiting sending

06/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964303

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXXX exceeds tolerance of $28,156.00.  Insufficient or no cure was provided to the borrower.

The Mortgage Broker Fee increased, however, a valid change of circumstance was not provided and no evidence of cure provided to the Borrower.

Reviewer Comment (2019-06-14): VCC provided. Buyer Comment (2019-06-14): Please see COC 4-1

06/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206964303

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Title Error: Title vesting does not concur with deed

The Security Instrument vesting includes "... joined by his wife XXXXXX", while the recorded warranty deed indicates the final vesting to be XXXXXX, a married man.

Reviewer Comment (2019-06-14): Security instrument and deed both represent the borrower as Married. Buyer Comment (2019-06-14): Married Man and Joined by his wife represents no material difference

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964303

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

-

Tax Liens were disclosed on the Borrower's credit report but there was no supporting documentation in file to confirm they have been satisfied.

Reviewer Comment (2019-06-14): XXXXXX received the credit report supplement dated 3/XXXX reflecting the tax liens release as of 9/XX. Buyer Comment (2019-06-14): Please see AUDIT CREDIT REPORT reflecting  Federal and State tax lien "Release"

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

206964303

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-2,816.00.

There was a change in Lender Credit amount with no valid change of circumstance provided in file.

Reviewer Comment (2019-06-14): VCC provided. Buyer Comment (2019-06-14): COC LE 5-20

06/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

206964315

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.43630% or Final Disclosure APR of 6.52100% is in excess of allowable threshold of APOR 4.66% + 1.5%, or 6.16000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-06-14): Client purXXXXXXs HPML compliant loans.

06/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

206964315

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-06-14): XXXXXX has elected to waive this exception.

06/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

206964315

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Borrower does not have the minimum active tradelines per guidelines.

Borrower has two open tradelines active for 1 month and 8 months vs program requirement of a minimum of 2 active and 1 inactive tradeline with a history of at least 12 months.  Lender approved exception.

Limited, but perfect, credit history and no public records. Reserves are 415,690 > program requirement of 110% of the loan amount + 3 months 224,380.96. DTI is 28.30686%, 21.69314% < program maximum of 50%. FICO Score of 668, 8 points > program requirement of 660.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-14): Client has elected to waive this exception based on compensating factors.

06/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207100753

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing the Fraud Report for both borrowers.

Reviewer Comment (2019-06-21): Rec'd fraud report. Buyer Comment (2019-06-21): fraudguard

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100753

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Asset documentation provided verifies reserves after closing of $11,130.62, which are insufficient to cover the required reserves of $13,818.00 (subject PITI of $2,303.00 x 6 months).

Borrower has a disposable income of $4,900. Co-borrower has job stability for 13 years as a XXXXXX

Originator Originator

Reviewer Comment (2019-06-21): Rec'd exception for insufficient reserves.

05/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100753

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-06-21): Waive per client request.

05/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207100753

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $834.50 exceeds tolerance of $375.00 plus 10% or $412.50.  Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance of $834.50 exceeds tolerance of $375.00 plus 10% or $412.50 due to an increase in Recording Fees without a valid Change of Circumstance. Evidence of cure for the increase of $422.00 was not provided.

Reviewer Comment (2019-06-21): Received Letter of Explanation, verified Proof of Delivery (per FedEx, package is schedule to be delivered on XXXXXX), Copy of Refund Check for $422.00 and Corrected CD required to cure.

06/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207100753

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for 10% tolerance violation of $422.00 was not provided.

Buyer Comment (2019-06-21): waive

06/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207100753

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $834.50 exceeds tolerance of $375.00 plus 10% or $412.50.  Sufficient or excess cure was provided to the borrower.

Buyer Comment (2019-06-21): waive

06/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207100761

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow xx acres vs. program maximum of 15 acres

Tradelines paid as agreed since last delinquency XXXXXX No farming or agricultural influence on the subject property.Subject has been recently updated with a new XXXX. Self-employed for the past 3 years as XXXXXX

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-21): Client has elected to waive this exception based on compensating factors.

06/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100761

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Asset Issue:  Gift funds are missing evidence of receipt

No evidence in file of Donor's ability or transfer of funds and receipt by Borrower or Closing Agent.

Reviewer Comment (2019-06-21): Wire receipt provided for both gift fund amounts of $25,000.00 Buyer Comment (2019-06-21): Please see FNMA GIFT FUNDS, and GIFT-WIRE RECEIPT; FNMA guidelines requires funds be transferred to the borrower in addition states that a settlement statement is acceptable documentation - page 3 of the final CD reflects $50,000 funds received also supported by Gift Wires held in escrow by the title company from xxxx which matches the Donor name on Gift Letter.

06/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100761

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing XXXXXX statement for XXXXXX business account XXXXXX, lender income analysis used figures from XXXXXX personal account XXXXXX in error.

Reviewer Comment (2019-06-21): Received correct bank stmt. Cleared. Buyer Comment (2019-06-21): Please see XXXXXX DEC Reviewer Comment (2019-06-21): Pending bank statement for review.

06/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100761

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-06-21): XXXXXX has elected to waive this exception.

06/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100761

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section A Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX reflects a Paid To party other than to lender or broker for fee within Origination Charges.

Invoice in file shows CDA fee paid to third party by way of lender.

Buyer Comment (2019-06-21): XXXXXX has elected to waive this exception Reviewer Comment (2019-06-21): IF a fee is not paid to Lender it should be disclosed in Section B as Borrower is not able to shop.  A Corrected CD and LOE are required to cure. Buyer Comment (2019-06-21): This is a pass through fee and not material

06/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good Faith Redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207100761

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Borrower waived appraisal timing rights, initial report rec'd by borrower XXXXXX per doc 94, evidence if/when final report was provided to borrower is missing from file.

Reviewer Comment (2019-06-21): Appraisal Receipt provided. Buyer Comment (2019-06-21): Please see Appraisal Receipt

06/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100761

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.94070% or Final Disclosure APR of 8.00100% is in excess of allowable threshold of APOR 4.58% + 1.5%, or 6.08000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-06-21): Appraisal Receipt provided. Buyer Comment (2019-06-21): Please see Appraisal Receipt

06/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100761

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Borrower waived appraisal timing rights, initial report rec'd by borrower XXXXXX per doc 94, evidence if/when final report was provided to borrower is missing from file.

Reviewer Comment (2019-06-21): Appraisal Receipt provided. Buyer Comment (2019-06-21): Please see Appraisal Receipt

06/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207100761

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Reviewer Comment (2019-06-21): Effective date is XXXXXX

06/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107141

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 9.52140% or Final Disclosure APR of 9.55500% is in excess of allowable threshold of APOR 4.18% + 1.5%, or 5.68000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-06-25): XXXXXX mortgage purXXXXXXs HPML compliant loans.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207107141

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

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

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

Buyer Comment (2019-06-25): XXXXXX has elected to waive

06/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207107141

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX HPML Threshold Test Non-Compliant

XXXXXX Higher-Priced Mortgage Loan: APR on subject loan of 9.52140% or Final Disclosure APR of 9.55500% is in excess of allowable threshold of APOR 4.18% + 1.5%, or 5.68000%.  Non-Compliant Higher Priced Loan.

Buyer Comment (2019-06-25): XXXXXX has elected to waive Buyer Comment (2019-06-25): XXXXXXhas elected to waive

06/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207107141

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure XXXXXX 12:00:00 AM was received.

Evidence of earlier receipt of revised LE missing from file.

Buyer Comment (2019-06-25): XXXXXX has elected to waive

06/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207107141

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller Closing Disclosure not located in the file.

Buyer Comment (2019-06-25): XXXXXX has elected to waive

06/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207107141

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

-

No evidence of payoff in file.

Reviewer Comment (2019-06-25): No longer enforceable due to the applicable state statute of limitations for MD of 6 years last reported date 6/2013. Reviewer Comment (2019-06-25): Received the article regarding State by State List of Statute of Limitations, however no specific information was provided. Condition remains.

06/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207107141

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue:Insufficient asset documentation.

-

Please provide an additional 2 months statements as < 60 days verified.

Reviewer Comment (2019-06-25): New account opened 5/XX19 < 60 days available - $25,000 deposit sourced from XXXXXX account.

06/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Loans cannot close in Trust.

Allow subject primary home loan to close in an XXXXXX vs. program requirement that only investment properties can be closed in an LLC.  Approved Lender Exception in file.

No public records. Borrowers have both been self-employed for over two years operating XXXXXX  which does business as XXXXXX Reserves are 42.12 months, 22.12 months > program requirement of 20 months. DTI is 39.45980%, 10.5402% < program maximum of 50%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-25): XXXXXX has elected to waive this exception based on compensating factors.

06/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: Closing Disclosure is incomplete

Final CD provided is missing top of pages 2-3 and incomplete.

Reviewer Comment (2019-06-25): Final CD provided wit complete pages 2-3. Buyer Comment (2019-06-25): See final CD provided - showing all pages Reviewer Comment (2019-06-25): Received trailing docs and the final CD, however the final CD dated XXXXXX remains cut off at the top of page 2-5. Please provide the final CD with all pages fully legible. Buyer Comment (2019-06-25): All pages provided Buyer Comment (2019-06-25): See final CD provided

06/07/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

Missing Document: Flood Insurance Policy not provided

Missing Flood Insurance declarations page.

Reviewer Comment (2019-06-25): Flood Insurance included in HOI policy.

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Title Error: Title vesting does not concur with deed

Co borrower, XXXXXX, is not listed on Title or the Security Instrument yet she is on the Note.

Reviewer Comment (2019-06-25): Agree with lender. Buyer Comment (2019-06-25): XXXXXX is a Managing Member of XXXXXX

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

Flood Insurance Error: Insurance premium was not provided.

Missing Flood Insurance policy.

Reviewer Comment (2019-06-25): Flood Insurance included in HOI policy.

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Coverage of $6,686,895.80 does not meet 80% of the estimated cost new

Reviewer Comment (2019-06-25): Received renewal policy. Condition cleared. Reviewer Comment (2019-06-25): Received renewal policy. Even with the additional coverage, the policy remains insufficient to cover 80% of the estimated cost to rebuild by $337,192.50. Conditions remains. Buyer Comment (2019-06-25): Updated Declaration page provided showing new policy period.  Additionally, policy jacket defines "Extended Rebuilding Cost" as being an additional 50% coverage added to the policy limits when the subject is being rebuilt from a total loss (see Part II. Property, section B.)  Please clear.

06/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing XXXX business bank statement account XXXXXX used for qualification.

Reviewer Comment (2019-06-25): Received required bank statement. Buyer Comment (2019-06-25): See bank statement provided

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Flood Insurance Escrow - Flood not Escrowed for Property in Flood Zone

Loan originated post December 2015, the subject property is in a flood zone, flood insurance is not escrowed.

Buyer Comment (2019-06-25): XXXXXX has elected to waive this exception.

06/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-06-25): XXXXXX has elected to waive this exception.

06/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX did not disclose the Finance Charge.

Final CD in file is incomplete, missing tops of pages 2-5.

Reviewer Comment (2019-06-25): AMC received required documents, exception is cleared. Buyer Comment (2019-06-25): Final CD provided

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX did not disclose the Total of Payments.

Final CD in file is incomplete, missing tops of pages 2-5.

Reviewer Comment (2019-06-25): AMC received required documents, exception is cleared. Buyer Comment (2019-06-25): Final CD provided

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Only CD in file was provided to the borrower at time of closing.

Reviewer Comment (2019-06-25): Received. Buyer Comment (2019-06-25): Initial CD provided

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $141,592.00 may be required.

Missing copy of Loan Estimate.

Reviewer Comment (2019-06-25): Received. Buyer Comment (2019-06-25): LE's provided

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Missing evidence disclosure was provided to the borrower at time of application.

Reviewer Comment (2019-06-25): Received. Buyer Comment (2019-06-25): ARM disclosure provided

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Missing evidence disclosure was provided to the borrower at time of application.

Reviewer Comment (2019-06-25): Received.

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Copy of disclosure in file was provided on XXXX19 yet application date is XXXX19.

Reviewer Comment (2019-06-25): Received.

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Missing evidence disclosure was provided to the borrowers at time of application.

Reviewer Comment (2019-06-25): Received.

06/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Lender acknowledged

No public records. Borrowers have both been self-employed for over two years operating XXXXXX  which does business as XXXXXX Reserves are 42.12 months, 22.12 months > program requirement of 20 months. DTI is 39.45980%, 10.5402% < program maximum of 50%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-25): XXXXXX has elected to waive this exception based on compensating factors.

06/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $141,592.00 and disclosure timing violations.

E-sign consent was not provided in loan file.

Reviewer Comment (2019-06-25): E-sign consent was not provided Buyer Comment (2019-06-25): Econsent provided for both borrowers

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Due to missing e-sign consent. Once received, compliance can be re-ran to determine compliance.

Buyer Comment (2019-06-25): XXXXXX has elected to waive this exception.

06/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

SSPL list was not included in the loan file.

Reviewer Comment (2019-06-25): List of service providers provided Buyer Comment (2019-06-25): SSPL provided

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $25,833.00 exceeds tolerance of $18,138.00 plus 10% or $19,951.80.  Insufficient or no cure was provided to the borrower.

Due to missing e-sign consent. Once received, compliance can be re-ran to determine compliance.

Reviewer Comment (2019-06-25): AMC received  Letter of Explanation, Copy of Refund Check, and Corrected CD. Buyer Comment (2019-06-25): See PCCD, LOX, copy of Refund Check and Tracking label provided. Reviewer Comment (2019-06-25): UPDATED: TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $930.50 exceeds tolerance of $550.00 plus 10% or $605.00.  Insufficient or no cure was provided to the borrower. Reviewer Comment (2019-06-25): No changed circumstance documentation located in the loan file. A PCCD, LOE, and copy of any refund check is required in order to address the exception. Buyer Comment (2019-06-25): Econsent provided

06/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $15,000.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Due to missing e-sign consent. Once received, compliance can be re-ran to determine compliance.

Reviewer Comment (2019-06-25): COC - rate lock and loan amount increase - confirmed from rate lock that rate was locked XXXXXX with a loan amount increase Reviewer Comment (2019-06-25): No changed circumstance documentation located in the loan file. A PCCD, LOE, and copy of any refund check is required in order to address the exception. Buyer Comment (2019-06-25): Econsent provided

06/07/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $6,000.00 exceeds tolerance of $5,000.00.  Insufficient or no cure was provided to the borrower.

Due to missing e-sign consent. Once received, compliance can be re-ran to determine compliance.

Reviewer Comment (2019-06-25): AMC received  Letter of Explanation, Copy of Refund Check, and Corrected CD. Buyer Comment (2019-06-25): See PCCD, LOX, copy of Refund Check and Tracking label provided. Reviewer Comment (2019-06-25): No changed circumstance documentation located in the loan file. A PCCD, LOE, and copy of any refund check is required in order to address the exception. Buyer Comment (2019-06-25): Econsent provided

06/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXXX exceeds tolerance of $32,205.00.  Insufficient or no cure was provided to the borrower.

Due to missing e-sign consent. Once received, compliance can be re-ran to determine compliance.

Reviewer Comment (2019-06-25): COC - rate lock and loan amount increase - confirmed from rate lock that rate was locked XXXXXX with a loan amount increase Reviewer Comment (2019-06-25): No changed circumstance documentation located in the loan file. A PCCD, LOE, and copy of any refund check is required in order to address the exception. Buyer Comment (2019-06-25): Econsent provided

06/07/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Flood Insurance Policy expires within 90 days of the Note Date.

Policy expires within 60 days of the Note Date.

Reviewer Comment (2019-06-25): Updated expiration date to XXXX2020. Buyer Comment (2019-06-25): Endorsement PCHO-FLD (XX06) is for Flood coverage - see policy jacket provided showing Flood endorsement included in coverage Reviewer Comment (2019-06-25): Renewal policy for borrower's flood insurance was not included in the trailing docs. Please provide the renewal policy for the flood insurance policy. Buyer Comment (2019-06-25): See updated Insurance Dec page provided and policy jacket for coverage.

06/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $930.50 exceeds tolerance of $550.00 plus 10% or $605.00.  Sufficient or excess cure was provided to the borrower.

Exceptions cured.

Reviewer Comment (2019-06-25): AMC received  Letter of Explanation, Copy of Refund Check, and Corrected CD.

06/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $6,000.00 exceeds tolerance of $5,000.00.  Sufficient or excess cure was provided to the borrower.

Exceptions cured.

Reviewer Comment (2019-06-25): AMC received  Letter of Explanation, Copy of Refund Check, and Corrected CD.

06/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107161

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

CDA provided; however, origination appraisal is missing.

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Credit

Credit

Public Records

Public Records/Collections/Charge Off does not meet guidelines.

-

Borrower has a foreclosure completed XXXXXX (34 months) vs program requirement of no foreclosure, bankruptcy, deed in lieu or short sale over past 48 months at standard LTVs and reserves.  An approved lender exception is provided based on compensating factors of credit score, credit history since bankruptcy/foreclosure, reserves, DTI, and length of self employment.

Reviewer Comment (2019-06-25): Loan meets guides as foreclosure > 48 months SPA5 guides allow a foreclosure > 48 months. Reviewer Comment (2019-06-25): Exception not required. Reviewer Comment (2019-06-25): Client has elected to waive this exception based on compensating factors.

06/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Appraisal Flipped Property Missing Information

Last Sales Price or Last Sales Date from the Primary Valuation or Contract Sales Price or Contract Sales Date are missing. Unable to determine compliance with TIL HPML Flipped Property Requirements.

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-06-25): XXXXXX has elected to waive this exception.

06/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX SB 1894

XXXXXX Predatory Lending Database Program (SB 1894) - Certificate of Compliance or Exemption not attached to mortgage for recording.

Reviewer Comment (2019-06-25): Subject is located in XXXXXX and document is not required. Buyer Comment (2019-06-25): Per XXXXXX (title closer)@XXXXXX, this is not a requirement in XXXXXX

06/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.86530% or Final Disclosure APR of 8.92300% is in excess of allowable threshold of APOR 4.56% + 2.5%, or 7.06000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Reviewer Comment (2019-06-25): Appraisal provided. Buyer Comment (2019-06-25): Appraisal uploaded for review.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207107162

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender approved exception to allow DTI of 45.402% vs program maximum of 43%.

Borrower has no public records. Borrower has been self employed for 14 years - XXXXXX Borrower's credit score of 706 > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-25): Client has elected to waive this exception based on compensating factors.

06/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107162

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 45.40280% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Lender approved exception to allow DTI of 45.402% vs program maximum of 43%.

Borrower has no public records. Borrower has been self employed for 14 years - XXXXXX Borrower's credit score of 706 > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-25): Client has elected to waive this exception based on compensating factors.

06/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107162

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX HPML Threshold Test Compliant

XXXXXX Higher-Priced Mortgage Loan: APR on subject loan of 7.49690% or Final Disclosure APR of 7.79500% is in excess of allowable threshold of APOR 4.66% + 1.5%, or 6.16000% Compliant Higher Priced Loan.

Buyer Comment (2019-06-25): XXXXXX has elected to waive

06/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107162

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $525.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing.

The appraisal fee increased by $25, however, a sufficient cure was disclosed on the final CD.

06/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207107162

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow the use of business funds of $xxxx5 for earnest money deposit coming directly from the business account vs program requirement that if funds in a business bank or brokerage account have not been transferred to the borrower's personal account, such funds may not be included in down payment and closing funds.

Borrower has no public records. Borrower has been self employed for 14 years - XXXXXX Borrower's credit score of 706 > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-25): Client has elected to waive this exception based on compensating factors.

06/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207107164

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-06-25): XXXXXX has elected to waive this exception.

06/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207139468

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Per documentation in file, the borrower received a copy of the appraisal on XXXXXX, which is prior to the final appraisal report date of XXXXXX. Because the final appraisal is dated after the subject loan closed on XXXXXX, a copy of the original appraisal is required to clear this exception.

Buyer Comment (2019-06-27): waive

06/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207139468

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final Closing Disclosure disclosed a Closing Date of XXXXXX. Deed of Trust was notarized on XXXXXX.

Reviewer Comment (2019-06-27): XXXXXX received PCCD correcting close date and LOE. Exception Cured. Buyer Comment (2019-06-27): see attached pccd and delivery

06/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207139468

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-06-27): Client Elects to waive Non-Material Exception

05/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207139468

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $1,687.50 exceeds tolerance of $1,642.50.  Insufficient or no cure was provided to the borrower.

Loan Discount Points of $1,642.50 were disclosed on the Closing Disclosure dated XXXXXX with a valid COC for the rate lock however, the Loan Discount Points increased to $1,687.50 on the Final Closing Disclosure without a valid COC Evidence of cure for the increase of $45.00 was not provided.

Reviewer Comment (2019-06-27): Received a COC for the loan amount increase on the Final CD. Buyer Comment (2019-06-27): loan amount changed at docs. coc attached

06/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207139468

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $450.00 exceeds tolerance of $375.00 plus 10% or $412.50.  Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance of $450.00 exceeds tolerance of $375.00 plus 10% or $412.50. File contains a COC for an increase in the title fees however, the reason for the change "New 3rd party fees not known at initial disclosures" is not valid reason for the fee increases. Evidence of cure for the increase of $38.50 was not provided.

Reviewer Comment (2019-06-27): XXXXXX received PCCD and final settlement statement indicating the recording fees charged totaled $137. Exception Cleared. Buyer Comment (2019-06-27): pccd and loe Reviewer Comment (2019-06-27): Confirmed Final Settlement Statement reflects $137 for the recording fees. A Corrected CD and LOE to the borrower is required to cure. No cure check is required for thee 10% fees as the actual fess paid is less,  However a Corrected CD and LOE to borrower is required. Post Close CD issued XXXXXX still reflects $450 for recording fees. Buyer Comment (2019-06-27): per final settlement statement actual recording fees were $137.00 Reviewer Comment (2019-06-27): Recording fees are mandated by the county and are not a shoppable fee.  They fall under the 10% allowance threshold.  The loan program was known at time of application and the documents to be recorded would have been known at that time.  A refund is due unless a valid COC can be provided. Buyer Comment (2019-06-27): Escrow provided fees at the time of CD therefore the initial recording fee was an estimate as the actual fee was not known at the time of disclosure. This is a valid change of circumstance based on section 1026.17(c)(2)(i) provides that if any information necessary for an accurate disclosure is unknown to the creditor, the creditor shall make the disclosure based on the best information reasonably available to the creditor at the time the disclosure is provided to the consumer. Reviewer Comment (2019-06-27): XXXXXX reviewed exception. The XXXXXX COC indicates an increase in the recording fee due to rider however a rider was known to be required at initial disclosure as the loan was an arm. Please provide corrected CD, LOE, and Refund Check to cure. Buyer Comment (2019-06-27): Borrower shopped for those title fees see attached coc

06/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207139468

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Appraisal  Re-Inspection Fee was not disclosed on the Initial Loan Estimate dated XXXXXX, but disclosed as $150.00 on the Initial Closing Disclosure dated XXXXXX and on the Final Closing Disclosure. COC issued on XXXXXX did not disclose the reason for the addition of this fee. Evidence of cure was not provided.

Reviewer Comment (2019-06-27): XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cured. Buyer Comment (2019-06-27): see attached pccd and delivery

06/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207139468

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for various 0% and 10% tolerance violations totaling $188.50 was not provided.

Buyer Comment (2019-06-27): waive

06/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207139472

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-06-27): Received lender's approval. Buyer Comment (2019-06-27): approval attached

04/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207139472

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Reviewer Comment (2019-06-27): Upon further research, exception has been cleared. Bank statement guidelines require 6 months PITI and do not require HOA dues to be included. Verified reserves after closing of $23,960.00 are sufficient to cover the required reserves of $23,509.14 (subject PITI of $3,918.19 x 6) months).

04/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207139472

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-06-27): Attestation approved by XXXXXX in file.

01/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207139472

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $7,800.00 on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

The appraisal reflects HOA fees of $1XXmonth = $1,368 annually.

Reviewer Comment (2019-06-27): Cured after the 60 day window expired. Client waives as EV3/C Reviewer Comment (2019-06-27): XXXXXX received PCCD correcting non escrowed property costs however the 60 day window to cure from discovery date (XX12) has passed. Unable to cure

06/27/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207139472

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation. (XXXXXX)

The CD reflects XXXXXX whereas the notary date on the security instrument is XXXXXX.

Reviewer Comment (2019-06-27): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207139472

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provded.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

Rate lock missing from file.

Reviewer Comment (2019-06-27): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207139472

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not provided.

Valuation Type: Appraisal / Valuation Report Date: XXXXXX

Reviewer Comment (2019-06-27): Received 442 Completion Cert. Buyer Comment (2019-06-27): 1004d attached Reviewer Comment (2019-06-27): Received a Certificate of Occupancy however, the subject property was appraised Subject to the completion of the front & side yard (patio area) grading/landscaping and installation of appliances. It cannot be verified that these items were required by XXXXXX building codes prior to the issuance of an Occupancy Permit. An appraisal completion cert from the original appraiser is required to clear this exception. Buyer Comment (2019-06-27): Certificate of Occupancy attached

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207139472

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

Credit Report: Original // Public Record Type: Collections / Balance: XXXXXX, Credit Report: Original // Public Record Type: Collections / Balance: XXXXXX, Credit Report: Original // Public Record Type: Collections / Balance: XXXXXX, Credit Report: Original // Public Record Type: Collections / Balance: XXXXXX

Reviewer Comment (2019-06-27): Upon further research, exception has been cleared.

04/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207194001

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Final Title Policy not in file. Title commitment policy amount was $xxxx

Reviewer Comment (2019-07-03): Corrected title commitment provided. Buyer Comment (2019-07-03): See Attached updated title report.

06/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207194001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided did not reflect an amount by which the fees exceeded the legal limit.

Reviewer Comment (2019-07-03): Fee paid to borrower chosen provider in Section C - No tolerance

06/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207194001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $173.40 exceeds tolerance of $125.00.  Insufficient or no cure was provided to the borrower.

Title Endorsement fee of $173.40 exceeds tolerance of $125.00. No cure was provided to the borrower

Reviewer Comment (2019-07-03): Fee paid to borrower chosen provider in Section C - No tolerance Buyer Comment (2019-07-03): Please provide the date and name of the document you are seeing the $173.40 endorsement fee that is out of compliance.  I do not see what you are referring to.

06/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207194001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Appraisal provided XXXXXX appraisal report date XXXXXX.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207208647

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on XXXXXX disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table.

The Calculating Cash to Close table indicates cash to close of $38,951.19.  The Summaries of Transactions table indicates cash to close of $39,337.19.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207208647

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 8.21670% is in excess of allowable threshold of Prime Mortgage Market Rate 3.63000% + 1.75%, or 5.38000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue:Insufficient asset documentation.

Missing source of funds for large deposit $19,000 on XXXXXX into XXXXXX acct#XXXXXX

Reviewer Comment (2019-07-03): XXXXXX provided - Business Account withdrawal done in two parts (15k & 4k) same day provided. Buyer Comment (2019-07-03): See LOX provided - Business Account withdrawal done in two parts (15k & 4k) same day

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Missing final CD for sale of borrower REO located at XXXXXX

Borrower has been self employed for 2 years and in the same line of work for 21 years. 34.731%% DTI on this bank statement documentation loan < 50% guideline max - 15.269% below program guideline maximum FICO is 695, 55 points > program requirement of 640 LTV is 84.996%, 5.004% < program max of 90%

Originator Originator Originator Originator

Reviewer Comment (2019-07-03): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-03): XXXXXX Exception provided. Reviewer Comment (2019-07-03): Net proceeds have been added to assets, however reserves are still short by 0.74 mon. Buyer Comment (2019-07-03): Final CD provided for exiting primary

06/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-07-03): Included invoice for HOI Buyer Comment (2019-07-03): See trailing documents

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing Verbal Verification of Employment with XXXXXX., confirming the borrower's current employment status and start date of employment.

Reviewer Comment (2019-07-03): VVOE provided Buyer Comment (2019-07-03): VVOE provided

06/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Provision) New York Subprime Loan (Ability to Repay not Verified)

XXXXXX Subprime Loan: File does not contain evidence that analysis of borrower's ability to repay was performed based on verified income, obligations, assets, and/or employment using PITI payment based on fully-indexed rate with fully-amortizing payment and taking into account  payments on any simultaneously-closed loans.

Reviewer Comment (2019-07-03): . Buyer Comment (2019-07-03): See trailing documents

06/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.60980% is in excess of allowable threshold of Prime Mortgage Market Rate 3.68000% + 1.75%, or 5.43000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-07-03): . Buyer Comment (2019-07-03): See trailing documents

06/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Reviewer Comment (2019-07-03): XXXXXX received E Consent dated XXXXXX. Exception Cleared. Buyer Comment (2019-07-03): E-Consent provided

06/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $17,023.40 and disclosure timing violations.

Missing E-Sign consent from from file.

Reviewer Comment (2019-07-03): XXXXXX received E Consent dated XXXXXX. Exception Cleared. Buyer Comment (2019-07-03): E-Consent provided

06/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208658

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.60980% is in excess of allowable threshold of Prime Mortgage Market Rate 3.68000% + 1.75%, or 5.43000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Report not provided.

Reviewer Comment (2019-07-03): Compliance Report provided. Buyer Comment (2019-07-03): Mavent provided

06/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207208664

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: 1003 Final is incomplete

The final 1003 disclosed income as Base Empl. Income.  Bank statement income should be disclosed as Other Income.  The Self Employed Box was not checked on the first page.

Reviewer Comment (2019-07-03): Corrected 1003 received. Cleared. Buyer Comment (2019-07-03): See trailing document

06/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

Initial LE was not provided but was listed on the disclosures provided at application.  Unable to determine if a box was checked for the servicing disclosure.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The final CD disclosed that the loan is not assumable; the Note disclosed that the loan is assumable.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception. Reviewer Comment (2019-07-03): PCCD received, LOE to the consumer is required in order to address the exception.

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Neither box was checked in the Demand Feature section of the Loan Disclosures in the final CD.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception. Reviewer Comment (2019-07-03): PCCD received, LOE to the consumer is required in order to address the exception.

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure PAD Fee

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX disclosed a Pad fee that was not allocated to a specific cost or service performed.

The final CD disclosed an Escrow Pad of $300.00.

Reviewer Comment (2019-07-03): XXXXXX received required documents, exception is cured. Buyer Comment (2019-07-03): Escrow State - Final CD provided with final Settlement Statement showing PAD fee removed

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Pad Refund Check if applicable, and Corrected CD

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD did not provide a tolerance cure for the increase to the Escrow Pad.

Reviewer Comment (2019-07-03): XXXXXX received required documents, exception is cleared.

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

Initial LE was not provided with the documents but was listed on the disclosures provided at application.

Reviewer Comment (2019-07-03): Initial LE provided Buyer Comment (2019-07-03): See trailing documents Reviewer Comment (2019-07-03): The only LE in file is from 5/XXXX.  Unable to address exception based on current data.available. Buyer Comment (2019-07-03): See Disclosure Tracking provided

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207208664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for PAD.  Fee Amount of $300.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Escrow Pad was added to the final CD without a valid change of circumstance.

Reviewer Comment (2019-07-03): XXXXXX received required documents, exception cured. Buyer Comment (2019-07-03): Escrow State - Final CD provided with final Settlement Statement showing PAD fee removed

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Please provide a revised exception revision with DTI at 53.34204% versus 51.852%.

Reviewer Comment (2019-07-03): 100%

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 53.34204% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Please provide a revised exception revision with DTI at 53.34204% versus 51.852%.

Overall monthly housing payment reduction of approximately $13,099.77. Paying off a private first mortgage. Perfect credit history including one closed mortgage reporting paid as agreed ( just once isolated 30-day late on a revolving card.) No public records. Borrower has employment stability for 3.85 years with XXXXXX 16 months of reserves exceeds program minimum of 12 months Credit score of 710 exceeds program minimum of 680 by 30 points

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-03): DTI is 51.852% vs program max of 50% Reviewer Comment (2019-07-03): Corrected deposits and usability. Buyer Comment (2019-07-03): See UW Final Income Calc Worksheet provided

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Reviewer Comment (2019-07-03): AMC received the ARM disclosure dated 4/2/19. Buyer Comment (2019-07-03): ARM disclosure provided

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Appraisal acknowledgment disclosure missing from the file

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Flood Insurance Escrow

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed Flood Insurance Reserves figures under Initial Escrow Payment at Closing that does not match amount per month calculation.

Flood insurance and excess flood combined

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Property Value

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed an Appraised Property Value that did not match the actual Property Value for the loan.

Appraised value verified with the lowest appraisal report

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

One CD provided

Reviewer Comment (2019-07-03): AMC received LEs, CD, and SSPL. Exception Cleared. Buyer Comment (2019-07-03): Initial CD provided

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $137,706.00 may be required.

LE missing from the file

Reviewer Comment (2019-07-03): AMC received LEs, CD, and SSPL. Exception Cleared. Buyer Comment (2019-07-03): LE's provided

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Missing from the file

Reviewer Comment (2019-07-03): AMC received LEs, CD, and SSPL. Exception Cleared. Buyer Comment (2019-07-03): SSPL provided

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207208667

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Please provide a revised exception revision with DTI at 53.34204% versus 51.852%.

Overall monthly housing payment reduction of approximately $13,099.77. Paying off a private first mortgage. Perfect credit history including one closed mortgage reporting paid as agreed ( just once isolated 30-day late on a revolving card.) No public records. Borrower has employment stability for 3.85 years with XXXXXX 16 months of reserves exceeds program minimum of 12 months Credit score of 710 exceeds program minimum of 680 by 30 points

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-03): DTI is 51.852% vs program max of 50% Reviewer Comment (2019-07-03): 100% Buyer Comment (2019-07-03): Please see revised Income Calc Worksheet - uploaded copies of April and May XX Bank Statements included in calc.

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Please provide a revised exception revision with DTI at 53.34204% versus 51.852%.

Reviewer Comment (2019-07-03): 100%

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208667

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Lender approved exception for Max DTI of 55% for loan amounts to $6,000,000

Overall monthly housing payment reduction of approximately $13,099.77. Paying off a private first mortgage. Perfect credit history including one closed mortgage reporting paid as agreed ( just once isolated 30-day late on a revolving card.) No public records. Borrower has employment stability for 3.85 years with XXXXXX 16 months of reserves exceeds program minimum of 12 months Credit score of 710 exceeds program minimum of 680 by 30 points

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-03): Client has elected to waive this exception based on compensating factors.

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Disclosure dated XXXX19 application date XXXX19.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

AMC received LEs, CD, and SSPL. The Credit Report Fee increased from $95 to $96.50 on the XX06 CD without a valid change of circumstance. Please provide COC if available or corrected CD, LOE, and refund check to cure.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $96.50 exceeds tolerance of $95.00.  Insufficient or no cure was provided to the borrower.

AMC received LEs, CD, and SSPL. The Credit Report Fee increased from $95 to $96.50 on the XX06 CD without a valid change of circumstance. Please provide COC if available or corrected CD, LOE, and refund check to cure.

Reviewer Comment (2019-07-03): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-07-03): Cure documents provided

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207208667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $96.50 exceeds tolerance of $95.00.  Sufficient or excess cure was provided to the borrower.

AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-07-03): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

06/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207358624

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $294.00 exceeds tolerance of $128.00 plus 10% or $140.80.  Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance of $294.00 exceeds tolerance of $128.00 plus 10% or $140.80. Evidence of cure for the increase of $153.20 was not provided.

Reviewer Comment (2019-07-26): Received a valid COC for the Loan Estimate dated XXXXXX that disclosed the reason for the increase in the recording fee from $126.00 to $198.00. Reviewer Comment (2019-07-25): The total of $153.20 includes the recording fee of $98.00 paid by the seller, which has been excluded. The COC provided on XXXXXX disclosed the change of circumstance as "Loan file was locked - recording fee - apr price change - change in loan amount". The COC did not disclose the reason for the increase in the recording fee therefore, the remaining 10% tolerance increase of $55.20 is valid. A COC that discloses the reason for the recording fee increase is required to clear this exception, or a Letter of Explanation to the borrower, Proof of Delivery, Copy of Refund Check for $55.20, and Corrected CD is required to cure this exception. Seller Comment (2019-07-24): hello - page 479 thru 482 in file is a change in circumstance LE which indicate the higher recording fees due a change that XXXXX implemented after the loan was taken.

07/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207358624

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for 10% tolerance violation of $153.20 was not provided.

Reviewer Comment (2019-07-26): Received a valid COC for the Loan Estimate dated XXXXXX that disclosed the reason for the increase in the recording fee from $126.00 to $198.00. Reviewer Comment (2019-07-25): The total of $153.20 includes the recording fee of $98.00 paid by the seller, which has been excluded. The COC provided on XXXXXX disclosed the change of circumstance as "Loan file was locked - recording fee - apr price change - change in loan amount". The COC did not disclose the reason for the increase in the recording fee therefore, the remaining 10% tolerance increase of $55.20 is valid. A COC that discloses the reason for the recording fee increase is required to clear this exception, or a Letter of Explanation to the borrower, Proof of Delivery, Copy of Refund Check for $55.20, and Corrected CD is required to cure this exception. Seller Comment (2019-07-24): page 479 thru 482 is a change in circumstance LE with increased recording fees based upon xxxx County increased recording fee schedule.

07/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207358624

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

Final Closing Disclosure reflects TIP of 116.956% but calculated TIP is 119.035%, which is outside of .003% tolerance. Loan was tested with the Index Value of 2.338% per the Early ARM Disclosure and with the Index Value of 2.3433% per the Compliance Report dated XXXXXX.

Reviewer Comment (2019-07-26): Received the Letter of Explanation and Corrected Closing Disclosure required to cure. Reviewer Comment (2019-07-25): Loan was retested using the updated index of 2.264% however, it did not clear this exception. Final Closing Disclosure reflects TIP of 116.956% but calculated TIP is 116.887%, which is still outside of .003% tolerance. A Letter of Explanation to the borrower and Corrected Closing Disclosure are required to cure this exception. Seller Comment (2019-07-24): index used date of closing is 2.264%

07/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207358624

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total of Payments that does not match the actual total of payments for the loan.

Final Closing Disclosure reflects TOP of $xxxx but calculated TOP is $xxxx, which is a variance of $22,386.91. Loan was tested with the Index Value of 2.338% per the Early ARM Disclosure and with the Index Value of 2.3433% per the Compliance Report dated XXXXXX.

Reviewer Comment (2019-07-26): Exception was previously cleared. No additional action is needed. Seller Comment (2019-07-25): MAVENT PAGE 2 UNDER LOAN FEATURES SHOW INDEX RATE OF 2.264% Reviewer Comment (2019-07-25): Received client attestation that the index used was 2.264% Reviewer Comment (2019-07-25): Please provide the documentation that verifies a different index was used at closing. None of the documents in the file verify an index of 2.264%. Seller Comment (2019-07-24): index used date of closing is 2.264%

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207358624

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Amount Financed

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed an Amount Financed that was not within tolerance of the actual amount financed for the loan.

Final Closing Disclosure disclosed an Amount Financed of $1,069,789.20; calculated Amount Financed is $1,071,017.20, which is a difference of $1,228.00 for the subject purchase transaction. Loan was tested with the Index Value of 2.338% per the Early ARM Disclosure and with the Index Value of 2.3433% per the Compliance Report dated XXXXXX.

Reviewer Comment (2019-07-25): Received client attestation that the index used was 2.264% Seller Comment (2019-07-24): index used is 2.264% - date of closing

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207358624

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Final Closing Disclosure disclosed a finance charge of $xxxx; calculated finance charge is $xxxx, which is a difference of $21,158.91 for the subject purchase transaction. Loan was tested with the Index Value of 2.338% per the Early ARM Disclosure and with the Index Value of 2.3433% per the Compliance Report dated XXXXXX.

Reviewer Comment (2019-07-25): Received client attestation that the index used was 2.264% Seller Comment (2019-07-24): index used date of closing 2.264%

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207358625

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

File is missing all approval documentation.

Reviewer Comment (2019-07-25): Received the lender's commitment approval.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207358625

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

File is missing the Secondary Valuation required for securitization.

Reviewer Comment (2019-07-25): Received the UCDP Submission Summary that verifies a collateral underwriter score of 2. Secondary Valuation not required.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207358625

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provided.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

Evidence of the Rate Lock was not provided in imaged file.

Reviewer Comment (2019-07-31): Exception has been reviewed by the compliance department with this response: "While I would not use the LE by itself, seeing how the LE must be sent within 3 days of the rate lock, the COC dated 6/XX19 reflects the LE is being issued as a result of the rate lock. As a result, I would comfortable using these together to backstop the rate lock occurred on 6/XX19." Reviewer Comment (2019-07-30): This exception has been escalated to our compliance department for review. Stay tuned! Seller Comment (2019-07-26): LOAN WAS LOCKED ON June 11,XX AS PER le AND DATED 6/XXXX AND NOTICE OF CHANGE IN CIRCUMSTANCE DATED 6/XXXX

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207358625

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

File is missing the Loan Originator Compensation Disclosure. Unable to determine if compensation was based on a term of the transaction.

Reviewer Comment (2019-07-25): Received the LO Compensation Disclosure.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207358625

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Final Closing Disclosure disclosed a finance charge of $xxxx; calculated finance charge is $xxxx, which is a difference of $4,756.29 for the subject purchase transaction. Loan was tested with the Index Value of 2.647% per the Early ARM Disclosure and with the Index Value of 2.3433% per the Compliance Report dated XXXXXX.

Reviewer Comment (2019-08-26): SitusAMC received required documents, exception is cured. Reviewer Comment (2019-08-19): Letter of Explanation, Shipping Label, Refund check for under disclosed amount, Corrected CD provided.  Please provide proof the package has shipped to the borrower.  Tracking information provided states the label was created but has not shipped yet. Reviewer Comment (2019-08-07): AMC reviewed the Note Section 4 Part C states the Note holder will round to the nearest .125%.  XXXX reviewed states no rounding with 0.00 as a rounding factor.  Note and XXXX do not match which created the finance charge under-disclosure. Seller Comment (2019-08-06): i have rerun my Mavent again and I am coming up with the same figures as on my final CD and I cannot figure where you are getting $447.29 under disclosed My figures match exactly and showing PASS through the XXXX SYSTEM.  Please help and Thank you. Reviewer Comment (2019-08-05): Finance charges match, and Index is at minimum available in time period (2.467) Loan is still under disclosed by $XXX.  A PCCD, LOE, copy of the refund check in the amount of $XXX and proof of delivery is required in order to address the exception. Reviewer Comment (2019-07-25): Loan was tested with the closest index of 2.24650% (XXXXXX) however, the updated index did not clear this exception. Seller Comment (2019-07-24): INDEX USED 2.247%

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207358625

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

Final Closing Disclosure reflects TIP of 106.923% but calculated TIP is 109.085%, which is outside of .003% tolerance. Loan was tested with the Index Value of 2.647% per the Early ARM Disclosure and with the Index Value of 2.3433% per the Compliance Report dated XXXXXX.

Reviewer Comment (2019-08-19): Letter of Explanation & Corrected Closing Disclosure provided Reviewer Comment (2019-08-07): AMC reviewed the Note Section 4 Part C states the Note holder will round to the nearest .125%.  Compliance Ease reviewed states no rounding with 0.00 as a rounding factor.  Note and Mavent do not match which created the finance charge under-disclosure. Seller Comment (2019-08-06): i have rerun my Mavent again and I am coming up with the same figures as on my final CD and I cannot figure where you are getting $447.29 under disclosed My figures match exactly and showing PASS through the MAVENT SYSTEM.  Please help and Thank you. Reviewer Comment (2019-08-05): Finance charges match, and Index is at minimum available in time period (2.467) Loan is still under disclosed by $447.29.  A PCCD, LOE, copy of the refund check in the amount of $447.29 and proof of delivery is required in order to address the exception. Reviewer Comment (2019-07-25): Loan was tested with the closest index of 2.24650% (XXXXXX) however, the updated index did not clear this exception. Seller Comment (2019-07-24): INDEX USED 2.247%

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207358625

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total of Payments that does not match the actual total of payments for the loan.

Final Closing Disclosure reflects TOP of $xxxx but calculated TOP is $xxxx, which is a variance of $4,756.29. Loan was tested with the Index Value of 2.647% per the Early ARM Disclosure and with the Index Value of 2.3433% per the Compliance Report dated XXXXXX.

Reviewer Comment (2019-08-26): SitusAMC received required documents, exception is cured. Reviewer Comment (2019-08-19): Letter of Explanation, Shipping Label, Refund check for under disclosed amount, Corrected CD provided.  Please provide proof the package has shipped to the borrower.  Tracking information provided states the label was created but has not shipped yet. Reviewer Comment (2019-08-07): AMC reviewed the Note Section 4 Part C states the Note holder will round to the nearest .125%.  Compliance Ease reviewed states no rounding with 0.00 as a rounding factor.  Note and Mavent do not match which created the finance charge under-disclosure. Seller Comment (2019-08-06): i have rerun my Mavent again and I am coming up with the same figures as on my final CD and I cannot figure where you are getting $447.29 under disclosed My figures match exactly and showing PASS through the MAVENT SYSTEM.  Please help and Thank you. Reviewer Comment (2019-08-05): Finance charges match, and Index is at minimum available in time period (2.467) Loan is still under disclosed by $447.29.  A PCCD, LOE, copy of the refund check in the amount of $447.29 and proof of delivery is required in order to address the exception. Reviewer Comment (2019-07-25): Loan was tested with the closest index of 2.24650% (XXXXXX) however, the updated index did not clear this exception. Seller Comment (2019-07-24): INDEX USED 2.247%

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207358625

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Loan Type

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Loan Type that does not match the actual loan type for the loan.

Final Closing Disclosure disclosed the Loan Type as Other. Subject loan is a Conventional Purchase.

Reviewer Comment (2019-07-25): Received Letter of Explanation and Corrected Closing Disclosure required to cure.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207358625

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note contains assumption verbiage, a Non Assumability Addendum was not provided, but the final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-07-25): Received Letter of Explanation and Corrected Closing Disclosure required to cure.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Missing

Reviewer Comment (2019-07-19): Finally received the Note.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207488014

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Missing

Reviewer Comment (2019-07-19): Finally received the approval.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provded.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

Reviewer Comment (2019-07-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Missing the NOTE, so UTD

Reviewer Comment (2019-07-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Dates confirmed

Buyer Comment (2019-07-19): please waive

06/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate Max Rate In Year

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on XXXXXX with an increasing rate disclosed the first date when the interest rate can reach the maximum that does not match the actual first date for the loan. (Final/XXXXXX)

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Max Amount

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

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Max Amount In Year

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

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan. (ProjSeq:2/657813)

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 3 that does not match the actual payment for the loan. (ProjSeq:3/657814)

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 4 that does not match the actual payment for the loan. (ProjSeq:4/657815)

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a maximum periodic principal and interest payment for payment stream 2 that does not match the actual maximum payment for the loan. (ProjSeq:2/657813)

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a maximum periodic principal and interest payment for payment stream 3 that does not match the actual maximum payment for the loan. (ProjSeq:3/657814)

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXXdisclosed a maximum periodic principal and interest payment for payment stream 4 that does not match the actual maximum payment for the loan. (ProjSeq:4/657815)

Figures confirmed based on CD provided

Reviewer Comment (2019-07-19): Finally received the Note to verify the ARM maximum interest rates.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488014

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX ___

Reviewer Comment (2019-07-19): Received Buyer Comment (2019-07-19): license Reviewer Comment (2019-07-19): Updated commentary:  Self-employed borrower.  Missing independent verification of the business verified through a disinterested third party (CPA, regulatory agency, licensing bureau or verification of a phone and address listing using the internet) within 10 calendar days of closing.

06/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207488019

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of $18,563.52 on Final Closing Disclosure provided on XXXXXX not accurate. (Final/XXXXXX)

Final CD reflects estimated property costs over year 1 of $18,563.52.  Calculated amount is $16,914.48 ($1,409.5XXmo).

Reviewer Comment (2019-07-19): Letter of Explanation & Corrected Closing Disclosure provided

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488019

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/XXXXXX)

The Seller Closing Disclosure is missing from the loan file.

Reviewer Comment (2019-07-19): Seller cd provided

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488019

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

The note for the subject is incomplete-missing pages 2-5.

Reviewer Comment (2019-07-19): Received all pages of the executed Note.

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207488019

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Missing Document: Rider - PUD not provided

The PUD Rider is missing from the loan file.

Reviewer Comment (2019-07-19): Received all pages of the executed PUD Rider.

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207488019

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-07-19): Waive per client request.

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207488020

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-07-19): Proof of sales proceeds was provided.

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488020

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Borrowers on this Bank Statement documentation loan have a disposable income of $9,273.50 Housing payment history clean for 34 months

Originator Originator

Reviewer Comment (2019-07-19): Client waived reserves for the subject loan.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488020

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-07-19): Rec'd fraud report.

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488020

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Rate Spread Threshold Test Non-Compliant

XXXXXX Rate Spread Home Loan: APR on subject loan of 6.93050% or Final Disclosure APR of 7.00800% is in excess of allowable threshold of APOR 4.99% + 1.5%, or 6.49000%.  Non-Compliant Rate Spread Home Loan.

YSP exception cleared.  Loan is a Compliant NC Rate Spread Loan. Regraded to EV2-B.

Reviewer Comment (2019-07-19): Waived at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488020

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Provision) North Carolina Rate Spread Home Loan (Charged Impermissible YSP)

XXXXXX Rate Spread Home Loan: Mortgage loan contains a yield spread premium.

Reviewer Comment (2019-07-19): Broker comp is based on 0.0125% of principal loan amount which is permissible under state law . No further evidence in file that fee is based on a term of the transaction. Exception cleared. Reviewer Comment (2019-07-19): Exception is being reviewed by our compliance department. Buyer Comment (2019-07-19): The loan does not have yield spread premium - we pay the brokers the same percentage on every file it isnt based on interest rate chosen

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488020

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

The master insurance policy does not reflect the borrowers' names or Lender information.

Reviewer Comment (2019-07-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488020

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Note is assumable and Closing Disclosure reflects loan is not assumable.

Reviewer Comment (2019-07-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488021

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

Missing Document: Credit Report not provided

Missing Credit report for the primary borrower - XXXXXX

Reviewer Comment (2019-07-19): Rec'd credit report. Buyer Comment (2019-07-19): xxx's credit report

05/10/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

Per credit guidelines, twelve months verification of rental history should be provided. If payment is made to a private party, twelve consecutive months cancelled checks, online printout from bill pay, or bank statements are required.  Per the final 1003, XXXXXX has been renting for the most recent 1.4 years.  A verification of acceptable rental payment history was not provided.  Using current $3,000 rent expense per final 1003 for audit.  This was in the "other financing section of the final 1003, but in the rent expense section of the initial 1003".  DTI TBD.  Additional requirements may apply.

Reviewer Comment (2019-07-19): Rec'd verification of $3,000 rental payments. Buyer Comment (2019-07-19): see vor Reviewer Comment (2019-07-19): Rec'd XXXXXX bank statements.  Missing bank statements/cancelled checks to verify 12 months of rental payments for XXXXXX

06/06/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

XXXXXX  are self-employed through the same business S-Corp (XXXXXX ).  Per guidelines, the most recent business return is required. The XX 1120S for XXXXXX  was not provided.

Borrower has a disposable income of $75,000 524 months reserves

Originator Originator

Reviewer Comment (2019-07-19): Rec'd exception for missing XX 1120S. Reviewer Comment (2019-07-19): The uploaded exception is to calculate income using XX distributions on K-1.  The condition is for missing XX business tax returns. Buyer Comment (2019-07-19): exception Reviewer Comment (2019-07-19): Full documentation guidelines require federal income tax returns for the most recent tax year. Buyer Comment (2019-07-19): we are using XX distributions reflected on the K-1 for XXXXXX which is the main business.  Also, all Sch E losses are completely offset by the W-2 and capital gains income. Reviewer Comment (2019-07-19): Need lender exception for deviation from guidelines. Buyer Comment (2019-07-19): income from XX k-1 and asset depletion used to qualify.  business income not used

06/06/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Both self employed borrowers (XXXXXX ) provided their most recent XX 1040.  Each of their 1040s evidenced self-employment through other various businesses, some of them evidencing non-passive losses.  However, either the XX Schedule K-1 for these other various businesses evidencing <25% ownership and/or the XX 106XX1120S needed to calculate income or loss was not provided.  No losses evidenced on the XX 1040 were accounted for in the investor's qualifying income at origination.  Per guidelines, underwriting should adhere to this document, except where no guidelines are noted we defer to FNMA standards.  FNMA guidelines require the other self-employment income to be analysed and accounted for. XXXXXX businesses not account for - XXXXXX XXXXXX  businesses not accounted for - XXXXXX

Borrower has a disposable income of $75,000 524 months reserves

Originator Originator

Reviewer Comment (2019-07-19): Client approved exception to waive XX business tax returns and use only the XX K-1 distributions for XXXXXX Buyer Comment (2019-07-19): please waive as our selections with AMC are that we dont need documentation on business that represent very little income or loss for the borrowers Reviewer Comment (2019-07-19): This exception is still valid.  Missing K-1s for all businesses reflected on 1040s to document percentage of ownership.  Please see all prior commentary. Buyer Comment (2019-07-19): please see upload Reviewer Comment (2019-07-19): The uploaded exception is to calculate income using XX distributions on K-1.  The condition is for missing K-1s for numerous businesses reflected on 1040s.  Upon receipt of K-1s, additional income documentation may be required. Buyer Comment (2019-07-19): please see exception uploaded Reviewer Comment (2019-07-19): Per guidelines, if the borrower has a 25% or greater ownership interest in a corporation, LLC, partnership or limited partnership, signed business federal tax returns with all schedules should be requested.  Unable to determine borrower's ownership percentage due to missing documentation.  Any deviation from written guidelines requires a written exception. Buyer Comment (2019-07-19): we are using XX distributions reflected on the K-1 for XXXXXX which is the main business.  Also, all Sch E losses are completely offset by the W-2 and capital gains income.

07/09/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX, Borrower: XXXXXX

Unable to determine length of employment through third party verification for XXXXXX

Borrower has a disposable income of $75,000 524 months reserves

Originator Originator

Reviewer Comment (2019-07-19): Rec'd exception for missing XX 1120S. Buyer Comment (2019-07-19): please see upload Reviewer Comment (2019-07-19): Still missing business tax returns. Buyer Comment (2019-07-19): XXXXXX

06/06/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Cash to Close: $549,844.46 Liquid Assets:  $51,317.29 + $7,144.24 + 50,000 + 53,000 = $161,461.53 Evidence of stock liquidation required in the amount of $549,844.46 - 161,461.53 = $388,382.93 Evidence of liquidation required per guidelines.  Stock liquidation from account ending XXXXXX  not provided.

Reviewer Comment (2019-07-19): File contains wire transfer confirmation to verify the liquidation of the non-bank assets. Buyer Comment (2019-07-19): the proof of liquidation is the liquidation itself by transferring the funds to escrow from the account.

07/09/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Credit Report: Original // Borrower: XXXXXX

A fraud report for XXXXXX was not provided.

Reviewer Comment (2019-07-19): Rec'd fraud report.

05/10/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Credit Report: Original // Borrower: XXXXXX

A fraud report for XXXXXX was not provided.

Reviewer Comment (2019-07-19): Rec'd fraud report

05/10/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Credit Report: Original // Borrower: XXXXXX

A fraud report for XXXXXX was not provided.

Reviewer Comment (2019-07-19): Rec'd fraud report.

05/10/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Credit Report: Original // Borrower: XXXXXX

A fraud report for XXXXXX was not provided.

Reviewer Comment (2019-07-19): Rec'd fraud report.

05/10/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488021

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-07-19): Rec'd fraud report.

05/10/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

D

B

D

B

A

A

A

A

N/A

N/A

No

207488022

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-07-19): document provided

03/20/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207488022

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Disclosure not evidenced in loan file.

Reviewer Comment (2019-07-19): Attestation approved by AMC in file.

01/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207488022

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Final CD reflects not assumable.  Note states assumable.

Reviewer Comment (2019-07-19): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207488022

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Processing Fee.  Fee Amount of $699.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (7334)

Fee not disclosed on LE.  No valid change of circumstance nor cure provided.

Buyer Comment (2019-07-19): unable to clear. past the 60 day window Reviewer Comment (2019-07-19): AMC review requirements indicate fees should be disclosed individually so the consumer can make an educated decision as to costs associated with their loan.  In this case, the fee was not properly disclosed.  In order to address this exception a PCCD, LOE, copy of refund check and proof of delivery required. Buyer Comment (2019-07-19): The processing fee was originally lumped together in the origination fee as seen on the LE and initial CD …

3

C

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207488022

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Final CD does not reflect an amount by which total closing costs exceeded the legal limit.

Reviewer Comment (2019-07-19): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207488022

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Missing 24 month bank statements for XXXXXX  and verification that borrower is 100% of business.  File contains bank stmts for XXXXXX ; borrower owns only 45% of each so unable to use to qualify.

Borrower has a disposable income of $22,702 DTI below max by 5% or greater. DTI: 38.75% 2.3 years in current home Housing history 0x30 for 12+ months

Originator Originator Originator Originator

Reviewer Comment (2019-10-24): Added addtl comp factors Reviewer Comment (2019-07-19): Waived with comp factors noted by lender Reviewer Comment (2019-07-19): XXXXXX bank statement guidelines dated XXXXXX under qualified borrowers "Borrowers must be 100% owners of the business if business statements are being used to qualify".  Please provide Lender exception approval. Buyer Comment (2019-07-19): Borrower doesn't need to be 100% owner of company, please clear

10/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207488026

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Hazard Insurance Policy has an effective date of XXXXXX which is after the loan closed on XXXXXX and disbursed on XXXXXX. A revised Hazard Insurance Policy with an effective date of XXXXXX or earlier, or a corrected Closing Disclosure that verifies the loan was disbursed on or after XXXXXX is required to clear this exception.

Reviewer Comment (2019-07-19): Rec'd settlement statement.  Coverage was in place at the time the loan funded XXXX18. Buyer Comment (2019-07-19): loan disbursed on the 21st

05/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488026

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing a full Fraud Report for the borrower.

Reviewer Comment (2019-07-19): Received borrower's Fraud Report.

05/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488026

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___

File is  missing the borrower's most recent paystub covering a 30-day period as required by XXXXXX Full Documentation guidelines.

Borrower on this Full Doc documentation loan has a disposable income of $17,400.32 745 representative FICO score > 680 guideline minimum - 65 points above guideline minimum 35.89% DTI on this Full Doc documentation loan < 50.00% guideline max - 14.11% below program guideline maximum

Originator Originator Originator

Reviewer Comment (2019-07-19): Client approved exception to waive the borrower's paystubs as required by the guidelines. Buyer Comment (2019-07-19): exception Reviewer Comment (2019-07-19): Borrower was qualified with wages and full doc guidelines require paystubs. A lender exception with compensating factors is required to clear this exception. Buyer Comment (2019-07-19): borrower does not receive paystubs

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-07-19): Client Elects to waive Non-Material Exception

05/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Final Closing Disclosure, Section F. Prepaids disclosed the annual Homeowner's Insurance Premium as $1,200.00 which does not match the monthly Homeowner's Insurance Premium of $104.70 which equates to $1,256.40 annually.

Buyer Comment (2019-07-19): please waive

06/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $575.00.  Insufficient or no cure was provided to the borrower.

Appraisal Fee was disclosed as $575.00 on the Initial Loan Estimate dated XXXXXX, but disclosed as $650.00 on the revised Loan Estimate dated XXXXXX and on the Final Closing Disclosure. COC issued on XXXXXX disclosed the reason for the change as "New 3rd party fees not known at initial disclosures. Appraisal - rush" however, the COC did not disclose what new information warranted a rush of the appraisal. Appraisal is dated XXXXXX and was delivered to the borrower on XXXXXX. In addition, the appraisal rush invoice was not issued from the appraisal company.  Evidence of cure for the increase of $75.00 was not provided.

Reviewer Comment (2019-07-19): Valid COC provided. Buyer Comment (2019-07-19): see email attached. Advised by broker of increased appraisal cost on 2/XX19 Reviewer Comment (2019-07-19): AMC reviewed exception. The appraisal fee increased on the XX13 CD. The COC indicates a rush for the appraisal however a valid change of circumstance is not identified. Please provide additional details regarding the change of circumstance or corrected CD, LOE, and refund check to cure Buyer Comment (2019-07-19): please disregard uploaded final settlement statement. it was for the wrong file. Buyer Comment (2019-07-19): final settlement statement attached. appraisal fee was 450.00

07/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for 0% tolerance violation of $75.00 was not provided.

Buyer Comment (2019-07-19): please waive

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488027

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Fraud report was not provided.

Reviewer Comment (2019-07-19): Received

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

File is missing the required Desk Review.

Reviewer Comment (2019-07-19): Rec'd CDA.

06/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

XX Tax returns and transcripts were not provided.

Reviewer Comment (2019-07-19): Received XX XXXXX tax return which meets XXXXXX foreign income guidelines. Buyer Comment (2019-07-19): 1099 income used to qualify is picked up business and reflects on XXXXXX tax return. no transcripts due to XXXXXX income

06/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

-

Fraud report was not provided.

Reviewer Comment (2019-07-19): Received

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Final CD reflects $5,124 for yearly HOA fee however appraisal reflects $3,396 ($283./month).

Reviewer Comment (2019-07-19): Confirmed from NMLS listed the 3 HOA fees and HOA Names - Exception cleared Buyer Comment (2019-07-19): nmls listing showing all 3 hoa fees Buyer Comment (2019-07-19): This Property has 3 HOA's; 1. XXXXXX- $249 quarterly 2. XXXXXX - $183 quarterly 3. XXXXXX - $283 Monthly The total monthly HOA for all 3 is $427 x 12=5124 annually

07/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207488027

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

12 month VOR was not provided.

Borrower has a disposable income of $7,575

Originator

Reviewer Comment (2019-07-19): Waived with comp factor noted. Buyer Comment (2019-07-19): exception Reviewer Comment (2019-07-19): File contains an e-mail from the borrower's company that the September XX rent was paid through the company. File is still missing a VOR or cancelled checks to verify 12 months of rent payments for the borrower's rental residence at XXXXXX

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Credit

1003

Document Error

Borrower(s) is not a U.S. Citizen, and the guideline required documentation was not provided.

-

Valid visa was not provided.

Reviewer Comment (2019-07-19): Drivers license in file per guidelines.

05/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Proof that appraisal was delivered to borrower was not provided

Buyer Comment (2019-07-19): please waive Reviewer Comment (2019-07-19): Received a duplicate appraisal waiver form. As of XXXXXX, still have not received proof of when the appraisal was actually delivered to the borrower. Buyer Comment (2019-07-19): appraisal acknowledgment

06/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

XXXXXX  foreign property owned, XXXXXX , and mortgage statement, tax and insurance provided however currency conversions were not provided.

Reviewer Comment (2019-07-19): Received tax certificate and insurance policy with currency conversions. Buyer Comment (2019-07-19): currency conversions for xxxx

06/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Qualifying income based on XX 1099 and  YTD P&L reflects negative income of $1,620,382. Qualifying income not supported by YTD P&L.

Reviewer Comment (2019-07-19): Received XX XXXXX tax return.

06/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Documented qualifying Assets for Closing of  ___ is less than Cash From Borrower ___.

Borrower was qualified with assets of $123,149.41 from XXXXXX  however, this is a retirement account in the name of the non-borrowing spouse only. Without proof from XXXXXX  to verify the borrower has withdrawal access to this retirement account, the funds cannot be used for closing and reserves. Remaining assets of $14,075.00 are insufficient to cover the funds for closing of $57,062.13.

Reviewer Comment (2019-07-19): Received LOE from non-borrowing spouse allowing access to funds. Buyer Comment (2019-07-19): loe

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488027

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Borrower was qualified with assets of $123,149.41 from XXXXXX brokerage account XXXXXX however, this is a retirement account in the name of the non-borrowing spouse only. Without proof from XXXXXX  to verify the borrower has withdrawal access to this retirement account, the funds cannot be used for closing and reserves. Remaining assets of $14,075.00 are insufficient to cover the required 6 months of reserves.

Reviewer Comment (2019-07-19): Received LOE from non-borrowing spouse allowing access to funds. Buyer Comment (2019-07-19): please see upload

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207488028

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-07-19): Received

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488028

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

More than 3 NSFs/Overdraft Transfers occurred in the most recent 12-month period.

57 NSF's in a 12 month period and no exception or explanation

Reviewer Comment (2019-07-19): Received borrower signed LOE for NSFs

06/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA NMLSR - Individual Originator License Status Not Approved

Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not in approved license status to conduct loan origination activities.

Reviewer Comment (2019-07-19): Received evidence the LO was licensed to represent the broker at the time of origination through closing.

07/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal Loan Originator Compensation - Individual LO Not NMLS Licensed at Time of Application

Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not NMLS licensed or registered at time of application.

Reviewer Comment (2019-07-19): Received evidence the LO was licensed to represent the broker at the time of origination through closing.

07/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Reviewer Comment (2019-07-19): Received a post-closing CD and LOE to the borrower that corrected the disbursement date to XXXXXX. Reviewer Comment (2019-07-19): Rec'd final settlement statement.  Please provide final CD and LOE to the borrower. Buyer Comment (2019-07-19): loan funded on the 7th

07/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Assumption language is on the note.

Reviewer Comment (2019-07-19): Waive per client request.

05/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Hazard is $584.04 a year and under prepaids it states $292.04 for 12 months.

Buyer Comment (2019-07-19): please waive

05/31/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Under disclosed by $709.11

Reviewer Comment (2019-07-19): Cleared with compliance re-run.

05/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488028

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

No VOM or cancelled checks on current mortgage

Housing payment history clean for 85 months Borrower has been self-employed for 4.87 years

Originator Originator

Reviewer Comment (2019-07-19): Lender approved exception to allow an e-mail in lieu of a VOM for the existing private mortgage. Reviewer Comment (2019-07-19): As of XXXXXX, still have not received a standard VOM from the private lien holder for the subject property. Per XXXXXX Underwriting guidelines, a mortgage not reported on the credit report must be verified with: A standard mortgage verification; loan payment history from the servicer; the borrower's canceled checks for the last twelve months; or the borrower's year-end mortgage account statement, provided the statement includes a payment receipt history, and, if applicable, canceled checks for the months elapsed since the year-end mortgage account statement was issued. File contains an e-mail from the private lien holder that the lender used for the VOM and the payoff of this loan however, the original Note was not provided to verify the loan terms as stated in the e-mail. A client exception with compensating factors to allow the e-mail in place of a standard VOM or 12 months cancelled checks is required to clear this exception. Reviewer Comment (2019-07-19): Rec'd credit supplement for REO property.  Still missing VOM for subject.

07/01/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-07-19): Rec'd loan approval.

05/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Missing secondary valuation product required for securitization.

Reviewer Comment (2019-07-19): Rec'd CDA

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Reviewer Comment (2019-07-19): Rec'd closing statement.  Coverage was in place at the time the loan funded XXXX18.

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-07-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Qualification Method not Matching ATR

Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender does not match the ATR payment calculation methods under 1026.43(c)(5).

Reviewer Comment (2019-07-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Verified per loan docs in file

Reviewer Comment (2019-07-19): Finally received acceptable 3rd party verification of the borrower's self-employment in accordance with the guidelines. Buyer Comment (2019-07-19): please see upload Reviewer Comment (2019-07-19): Received a funder attestation that the borrower's business was verified on XXXXXX which is not a 3rd party verification and cannot be used in lieu of the actual dated verification. Exception remains. Reviewer Comment (2019-07-19): In order to comply with ATR, lenders must verify information they considered using reliable third-party records. Imaged file doesn't contain any third party verification of borrower's self employment/income status. Lender provided an internet printout of the business name a registrant as a stip in response to this exception, however it is undated and unable to determine if it was obtained prior to consummation as part of the lending decision. Exception remains. Reviewer Comment (2019-07-19): Rec'd printout from the OC Recorder. Buyer Comment (2019-07-19): please see business license uploaded Reviewer Comment (2019-07-19): Unable to waive. Reviewer Comment (2019-07-19): Ok to waive per client.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - Bank Statements

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current employment status using reasonably reliable third-party records. (XXXXXX)

Verified per loan docs in file

Reviewer Comment (2019-07-19): Finally received acceptable 3rd party verification of the borrower's self-employment in accordance with the guidelines. Buyer Comment (2019-07-19): please see upload Reviewer Comment (2019-07-19): Received a funder attestation that the borrower's business was verified on XXXXXX which is not a 3rd party verification and cannot be used in lieu of the actual dated verification. Exception remains. Reviewer Comment (2019-07-19): In order to comply with ATR, lenders must verify information they considered using reliable third-party records. Imaged file doesn't contain any third party verification of borrower's self employment/income status. Lender provided an internet printout of the business name a registrant as a stip in response to this exception, however it is undated and unable to determine if it was obtained prior to consummation as part of the lending decision. Exception remains. Reviewer Comment (2019-07-19): Rec'd printout from the OC Recorder. Buyer Comment (2019-07-19): business license uploaded

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Bank Statements

Ability to Repay (Dodd-Frank 2014): Unable to verify Bank Statement income using reasonably reliable third-party records. (XXXXXX)

Verified per loan docs in file

Reviewer Comment (2019-07-19): Finally received acceptable 3rd party verification of the borrower's self-employment in accordance with the guidelines. Reviewer Comment (2019-07-19): Received a funder attestation that the borrower's business was verified on XXXXXX which is not a 3rd party verification and cannot be used in lieu of the actual dated verification. Exception remains. Reviewer Comment (2019-07-19): In order to comply with ATR, lenders must verify information they considered using reliable third-party records. Imaged file doesn't contain any third party verification of borrower's self employment/income status. Lender provided an internet printout of the business name a registrant as a stip in response to this exception, however it is undated and unable to determine if it was obtained prior to consummation as part of the lending decision. Exception remains. Reviewer Comment (2019-07-19): Rec'd undated printout from the OC Recorder. Reviewer Comment (2019-07-19): Rec'd printout from the OC Recorder. Buyer Comment (2019-07-19): business license uploaded

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Verified per loan docs in file

Reviewer Comment (2019-07-19): Finally received acceptable 3rd party verification of the borrower's self-employment in accordance with the guidelines.

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

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

Verified per final CD dated XXXXXX

Reviewer Comment (2019-07-19): Initial CD e-signed XXXXXX Buyer Comment (2019-07-19): the CD was prepared on the 18th but the closing date was the xxth

05/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD. (Final/XXXXXX)

Verified per final CD dated XXXXXX

Reviewer Comment (2019-07-19): Waive per client.

01/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Notice of Special Flood Hazard Disclosure Not Provided Timely

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

disclosures provided to us were dated the same date as closing.

Reviewer Comment (2019-07-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Flood Insurance Escrow - Flood not Escrowed for Property in Flood Zone

Loan originated post December 2015, the subject property is in a flood zone, flood insurance is not escrowed.

there is no flood ins payment its covered by the condo policy.

Reviewer Comment (2019-07-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207488045

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

06/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207488048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

06/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

Seller CD missing

Reviewer Comment (2019-07-19): Seller CD provided Buyer Comment (2019-07-19): Please see Sellers CD uploaded.

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488048

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Issue:  Ineligible borrower

Borrower is the Owner of XXXXXX vs. program requirement that borrower may not be XXXXXX .  Approved Lender Exception in file.

No late payments on credit in 50 months (last late XXXXXX, 30 day on revolving account).  No public records. Borrower has been XXXXXX for the past 1.64 years and has 27 years in the same line of work.

Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-19): Client has elected to waive this exception based on compensating factors.

06/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $800.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207488049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-07-19): XXXXXXhas elected to waive this exception.

07/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207488049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207488050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

06/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207488050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for Verification Of Tax Return Fee of $50 was not provided.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

06/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207488050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-2,178.13  is less than amount of binding Lender Credit previously disclosed in the amount of $-4,356.00.

Zero Percent Tolerance exceeded for Lender Credits.

Reviewer Comment (2019-07-19): COC - rate lock Buyer Comment (2019-07-19): Origination credit decreased to 100.625% from 101.25%. COC uploaded.

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207488050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Tax Return Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Fee was not disclosed on initial Loan Estimate. Fee was re-disclosed to $50 on LE dated XXXXXX, but the file does not have a valid change of circumstance for the increase in fee. No evidence in file of cure provided to Borrower. Cure of $100 provided on final CD is only sufficient to cure Appraisal Fee.

Reviewer Comment (2019-07-19): XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-07-19): PCCD Documentation uploaded for review. Reviewer Comment (2019-07-19): XXXXXX received $50 cure check and mailing label. Please provide Post Close CD and LOE to borrower. Buyer Comment (2019-07-19): PCCD/LOE/Label uploaded. Reviewer Comment (2019-07-19): PCCD, LOE and Label  not located in loan file or trailing documents.  Please re-upload. Buyer Comment (2019-07-19): PPCCD/LOX/Refund/Label uploaded for your review. Reviewer Comment (2019-07-19): XXXXXX received Change of Circumstance forms.  Verification Of Tax Return Fee was added to the LE issued XXXXXX.  COC forms received are dated XXXXXX, XXXXXX and XXXXXX.  Valid COC required for Verification Of Tax Return Fee or cure required to borrower. Buyer Comment (2019-07-19): 5/23 Change of circumstance uploaded.

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207488050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $500.00.  Insufficient or no cure was provided to the borrower.

Cure of $100 provided on the final CD.

Reviewer Comment (2019-07-19): $100 cure provided at closing for appraisal fee increase. Buyer Comment (2019-07-19): Tolerance cure of $100 was given on 6/19 CD for appraisal fee being $100 higher. Change of circumstance uploaded.

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207488050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Tax Return Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-07-19): XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207488050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower.

XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-07-19): XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207488051

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Loan program requires a minimum of 3 months reserves while the Borrower only has available 2 months. A Lender Exception was granted to allow loan to proceed without sufficient reserves.

Borrower's credit history confirms paid as agreed since discharge of bankruptcy in XXXXXX Borrower has been self-employed in the same line of work for the past 15 years. The Borrower's qualifying score of 703 is 23 points higher than the minimum required of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-19): Client has elected to waive this exception based on compensating factors.

06/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488051

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

The DTI exceeded the maximum allowable due to a lower calculation of qualifying income caused by additional exclusions of deposits, as well as a debt with XXXX in the amount of $43 per month disclosed on the credit report was not included in the ratios at time of origination.

Borrower's credit history confirms paid as agreed since discharge of bankruptcy in XXXXXX Borrower has been self-employed in the same line of work for the past 15 years. The Borrower's qualifying score of 703 is 23 points higher than the minimum required of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-19): DTI is 47.033% vs program max of 43% for 90% LTV. Buyer Comment (2019-07-19): Revised credit exception uploaded for review.

06/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

This disclosure was not provided in file and there was no mortgage Broker fee disclosed on the Final CD.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

06/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

ATR Risk is caused by excessive DTI ratio.

Reviewer Comment (2019-07-19): Client waive the DTI with compensating factors. Reviewer Comment (2019-07-19): Incorrectly waived. Reviewer Comment (2019-07-19): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-19): Please see revised exception  uploaded 6/25, tab D251

06/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

ATR Risk is caused by excessive DTI ratio.

Reviewer Comment (2019-07-19): DTI is 47.033% vs program max of 43% for 90% LTV.

06/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 48.00501% significantly exceeds the guideline maximum of 43.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

The DTI exceeds the maximum allowable due to a lower calculation of income and the addition of debt not considered in ratios at time of origination.

Borrower's credit history confirms paid as agreed since discharge of bankruptcy in XXXXXX Borrower has been self-employed in the same line of work for the past 15 years. The Borrower's qualifying score of 703 is 23 points higher than the minimum required of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-19): DTI is 47.033% vs program max of 43% for 90% LTV.

06/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

The final CD did not disclose the number of months collected for property tax prepaids but only indicates it was collected for XXXXXX

Reviewer Comment (2019-07-19): Letter of Explanation & Corrected Closing Disclosure provided

06/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488051

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

Insufficient Verification of Rental History.

Borrower documented rental history through bank statements, however, part of February rent was in cash and cannot be verified. The Lender granted an exception to proceed with documentation available.

Borrower's credit history confirms paid as agreed since discharge of bankruptcy in XXXXXX Borrower has been self-employed in the same line of work for the past 15 years. The Borrower's qualifying score of 703 is 23 points higher than the minimum required of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-19): Client has elected to waive this exception based on compensating factors.

06/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488051

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Subject loan program requires a business license or CPA letter confirming the existence and ownership of business, however, the Borrower's line of work does not require a business license and a CPA is also not utilized. The Lender granted an exception accepting work reference letters in lieu of the required documentation.

Borrower's credit history confirms paid as agreed since discharge of bankruptcy in XXXXXX Borrower has been self-employed in the same line of work for the past 15 years. The Borrower's qualifying score of 703 is 23 points higher than the minimum required of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-19): Client has elected to waive this exception based on compensating factors.

06/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488051

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Reviewer Comment (2019-07-19): XXXXXX received the updated title commitment with proposed insured amount if $xxxx. Buyer Comment (2019-07-19): Revised Title Policy uploaded

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

no tolerance amount provided.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

06/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title Misc Charges.  Fee Amount of $182.50 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Fee on CD listed to an unknown party.

Reviewer Comment (2019-07-19): XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-07-19): PCCD/LOX/Refund/Label uploaded.

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title Misc Charges.  Fee Amount of $182.50 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-07-19): XXXXXX received PCCD indicating cure, LOE, and Refund Check. Exception Cured. Buyer Comment (2019-07-19): Documentation was previously provided for the cure, please update this exception.

06/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207488051

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 46.91709% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower's credit history confirms paid as agreed since discharge of bankruptcy in XXXXXX Borrower has been self-employed in the same line of work for the past 15 years. The Borrower's qualifying score of 703 is 23 points higher than the minimum required of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-19): Client elects to waive the exception with verified compensation factors

06/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688253

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Lender approval not provided

Reviewer Comment (2019-08-09): Received lender's approval. Buyer Comment (2019-08-09): see attached

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provded.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

Rate Lock not provided

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Assumption language present in Note, Final CD disclosed not assumable

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

Variance caused by monthly hazard calculated payment $176.00 vs Final CD monthly hazard $168.25.

Reviewer Comment (2019-08-09): AMC received HOI indicating premium of $XX. Exception Cleared. Buyer Comment (2019-08-09): See attached Evidence of Insurance; Premium is $2,019  = $168.25 as reflected on the cd Buyer Comment (2019-08-09): see attached

04/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (XXXXXX)

Variance caused by monthly hazard calculated payment $176.00 vs Final CD monthly hazard $168.25.

Reviewer Comment (2019-08-09): AMC received HOI indicating premium of $XX. Exception Cleared.

04/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (XXXXXX)

Variance caused by monthly hazard calculated payment $176.00 vs Final CD monthly hazard $168.25.

Reviewer Comment (2019-08-09): AMC received HOI indicating premium of $XX. Exception Cleared.

04/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (XXXXXX)

Variance caused by monthly hazard calculated payment $176.00 vs Final CD monthly hazard $168.25.

Reviewer Comment (2019-08-09): AMC received HOI indicating premium of $XX. Exception Cleared.

04/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (XXXXXX)

Variance caused by monthly hazard calculated payment $176.00 vs Final CD monthly hazard $168.25.

Reviewer Comment (2019-08-09): AMC received HOI indicating premium of $XX. Exception Cleared.

04/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/632064)

Variance caused by monthly hazard calculated payment $176.00 vs Final CD monthly hazard $168.25.

Reviewer Comment (2019-08-09): AMC received HOI indicating premium of $XX. Exception Cleared.

04/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Disclosed value $0.00, Calculated value $75.00.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Re-Issue Fee.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (75117)

Cost to cure $75.00 due Borrower.  Fee was not disclosed on initial LE or by way of valid change in circumstance.

Reviewer Comment (2019-09-18): Per XXXXXX e-mail on XXXXXX: #Please review fss attached.  The additional credit report fee was n/a on the fss so there should not be a tolerance violation." This exception has been re-reviewed by our compliance department with this response: "The FSS provided is not signed and does not have the same stamped certification as the estimated one in file and does not appear to correspond to the format and values of the preliminary in the loan file.  Also, the amounts on the FSS do not match the final CD (discrepancies in settlement fee, recording fees, notary/signing fee, etc.).  1026.19(f)(2)(iii) requires creditors to issue a PCCD if figures on the CD become inaccurate and the inaccuracy results in a change to an amount actually paid by the consumer from the one disclosed on the CD.  There is no PCCD within 30 days reflecting fee changes shown on the FSS provided. As it has been more than 6 months from closing, SitusAMC will accept a copy of final settlement statement sent directly by settlement agent to SitusAMC as basis for determination of actual amounts charged at consummation." Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): AMC received XX19 COC indicating credit report fee increased due to rapid re score however a valid change of circumstance is not indicated as to why this was ordered. Please provide additional details for review. The 60 day window to cure from discovery date (XX11) has passed, therefore exception is not able to be cured. Buyer Comment (2019-08-09): COC attached

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Disclosed date XXXX18, actual date XXXXXX.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688253

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/XXXXXX)

The appraisal was provided to the borrower on a date that is prior to the date the report was signed, indicating changes were made to the initial report.  Please provide evidence that all updated versions of the appraisal were provided to the borrower.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688259

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-08-09): Rec'd fraud report. Buyer Comment (2019-08-09): fraudguard hunsche

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688259

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688259

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal LO Compensation Dual Compensation Dodd Frank

Loan Originator Compensation: Dual compensation received from both a consumer and person other than consumer.

Reviewer Comment (2019-08-20): Lender provided evidence the Processing fee was paid to a thrid party. Reviewer Comment (2019-08-20): Reopened exception Reviewer Comment (2019-08-09): The broker agreement referenced by client in prior responses doesn't impact this exception. That agreement is relevant for a different exception. This exception has been confirmed by our compliance department and remains, it is un-curable post closing. Reviewer Comment (2019-08-09): Our compliance department has reviewed this exception with this response: "When the broker receives compensation from the consumer and the broker receives compensation from the lender, that is a valid exception and it is not something that can be cured post consummation." Buyer Comment (2019-08-09): ***PLEASE CLEAR*** We have provided our broker agreement which shows that all transactions are based on a set compensation and not subject to terms of the transaction

08/20/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688259

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AP Table Subsequent Changes

TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Disclosure provided on XXXXXX disclosed a Subsequent Changes period that does not match the actual terms for the loan. (Final/XXXXXX)

AP Table Subsequent Changes is blank, calculated change is 1 Every Year.

Reviewer Comment (2019-08-09): AP Table correctly disclosed on all CDs in file. Buyer Comment (2019-08-09): the subsequent changes show every year on all 3 CD's in Acuity

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688259

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX ___

A YTD P&L covering the period since last tax return was filed as required per guidelines is missing from file.

Housing payment history clean for 84 months 33.14 months reserves > 12 months guideline minimum Borrower has residual income of $17,475.69

Originator Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to waive the guideline required P&L statement for the borrower's Schedule C business. Reviewer Comment (2019-08-09): Borrower was qualified with Schedule C income using the XX personal tax return. XXXXXX Full Doc guidelines require a year-to-date profit and loss statement covering the period since the last tax return was filed and subject loan closed XXXXXX. A client approved exception with verified compensating factors is required to waive the guideline required year-to-date P&L statement and this exception. Buyer Comment (2019-08-09): this is a full doc loan and P&L's are not required it's UW discretion *** please clear***

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688259

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section A Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX reflects a Paid To party other than to lender or broker for fee within Origination Charges.

Based on the Settlement statment provided, the processing fee was paid to a third party provider and not to the broker.

Reviewer Comment (2019-08-20): Waive per client request.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688260

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-09): Received lender's approval. Buyer Comment (2019-08-09): approval attached

04/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688260

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Reviewer Comment (2019-08-09): Received post-disaster inspection, which verifies no damage to the subject property in the last FEMA Disaster. Buyer Comment (2019-08-09): DAIR attached

04/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688260

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Guidelines require total assets/120 months for asset depletion and at of origination, underwriter divided total assets/60 months. At time of origination, borrower was qualified with assets for depletion $300,000.00. After closing costs, assets available for asset depletion total $226,747.74.

785 representative FICO score > 680 guideline minimum - 105 points above guideline minimum

Originator

Reviewer Comment (2019-08-09): Client approved an exception with only 1 verified compensating factor to allow asset depletion income to be calculated over 60 months (guidelines require 120 months) and a DTI up to 55%. Buyer Comment (2019-08-09): lender exception to use 5 year asset depletion Buyer Comment (2019-08-09): Please see upload Reviewer Comment (2019-08-09): Lender used $300,000.00 in assets depleted over 60 months and qualified the borrower with monthly Asset Depletion income of $5,000.00 and a DTI of 53.64%. Verified assets of $498,991.62 less funds for closing of $XXXXXX, less 6 months required PITI reserves of $27,433.08 = $221,814.66 remaining assets to be depleted which results in a monthly income of $1,848.46 and a DTI of 81.01%.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688260

XXXXXX

XXXXXX

Credit

System

General

Valuation address does not match Note address.

Valuation Type: Appraisal / Valuation Report Date: XXXXXX

Note reflects subject unit xxx; appraisal reflects subject unit xxx.

Reviewer Comment (2019-08-09): Received Reviewer Comment (2019-08-09): As of XXXXXX, still have not received a corrected appraisal. Appraisal provided in the file reflects the subject unit number as XXXXXX however, the Note, Condo Rider and Preliminary Title verify the subject unit number is XXXXXX

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-08-09): Attestation approved by AMC in file.

01/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Subject loan does not meet the requirements of Non-QM due to a calculated DTI of 81.01%.

Reviewer Comment (2019-08-09): Client approved an exception with only 1 verified compensating factor to allow asset depletion income to be calculated over 60 months (guidelines require 120 months) and a DTI up to 55%. Buyer Comment (2019-08-09): Please see upload

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 81.01645% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Reviewer Comment (2019-08-09): Client approved exception to allow the asset depletion income to be calculated over 60 months (guidelines requires 120 months) and a DTI up to 55%. Reviewer Comment (2019-08-09): Updated from: Ability to Repay (Dodd-Frank XX): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 80.48612% significantly exceeds the guideline maximum of 50.00%.  (DTI Exception cannot be compensated to a lower grade.) Reviewer Comment (2019-08-09): Lender used $300,000.00 in assets depleted over 60 months and qualified the borrower with monthly Asset Depletion income of $5,000.00 and a DTI of 53.64%. Verified assets of $498,991.62 less funds for closing of $XXXXXX, less 6 months required PITI reserves of $27,433.08 = $221,814.66 remaining assets to be depleted which results in a monthly income of $1,848.46 and a DTI of 81.01%.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $7,800.00 on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

CD Non-Escrowed Property Costs over Year 1 $10,063.68. Calculated Non-Escrowed Property Costs over Year 1 per 1073; $838.00*12=$10,056.00.

Reviewer Comment (2019-08-09): Received Letter of Explanation and Corrected CD required to cure. Because the cure timeline has not been met, the exception cannot be cleared. Buyer Comment (2019-08-09): PCCD reflecting $10,056

3

C

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI

Reviewer Comment (2019-08-09): Client approved an exception with only 1 verified compensating factor to allow asset depletion income to be calculated over 60 months (guidelines require 120 months) and a DTI up to 55%. Buyer Comment (2019-08-09): Please see upload Reviewer Comment (2019-08-09): Due to a calculated DTI of 81.01%, the subject loan is at ATR Risk.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids. (Final/XXXXXX)

Final CD issued XXXXXX, Section F. Prepaids, Property Taxes, field for months is blank.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provded.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

Rate Lock Agreement not provided

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

The final CD discloses the loan is not assumable, the note contains assumption language.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688260

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 53.55951% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Exception revised for asset depletion income calculation.

785 representative FICO score > 680 guideline minimum - 105 points above guideline minimum

Originator

Reviewer Comment (2019-08-09): Client approved an exception with only 1 verified compensating factor to allow asset depletion income to be calculated over 60 months (guidelines require 120 months) and a DTI up to 55%.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Fannie Mae 2014 - 3% Points and Fees

Fannie Mae 2014 3% Points and Fees Test.  Points and Fees on subject loan of XX% is in excess of the investor allowable maximum of  3.00000% of the Federal Total Loan Amount. Points and Fees total $XXXX on a Federal Total Loan Amount of $XXXXXX vs. an investor allowable total of $XXXX (an overage of $XX or .02240%).

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-08-09): Attestation approved by AMC in file.

01/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

Final CD reflects amount of escrowed property costs over year 1 of $6,279.  Calculated amount is $6,261.96 ($521.8XXmo).

Reviewer Comment (2019-08-09): AMC received required documents, the exception is cured. Buyer Comment (2019-08-09): pccd and delivery

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (XXXXXX)

Final CD reflects escrow payment of $523.25.  Calculated escrow payment is $521.83.  Lender used hazard amount of $80.7XXmo, policy reflects $79.3XXmo.

Reviewer Comment (2019-08-09): AMC received required documents, the exception is cured. Buyer Comment (2019-08-09): please see upload

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (XXXXXX)

Final CD reflects escrow payment of $523.25.  Calculated escrow payment is $521.83.  Lender used hazard amount of $80.7XXmo, policy reflects $79.3XXmo.

Reviewer Comment (2019-08-09): AMC received required documents, the exception is cured. Buyer Comment (2019-08-09): please see upload

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (XXXXXX)

Final CD reflects escrow payment of $523.25.  Calculated escrow payment is $521.83.  Lender used hazard amount of $80.7XXmo, policy reflects $79.3XXmo.

Reviewer Comment (2019-08-09): AMC received required documents, the exception is cured. Buyer Comment (2019-08-09): please see upload

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (XXXXXX)

Final CD reflects escrow payment of $523.25.  Calculated escrow payment is $521.83.  Lender used hazard amount of $80.7XXmo, policy reflects $79.3XXmo.

Reviewer Comment (2019-08-09): AMC received required documents, the exception is cured. Buyer Comment (2019-08-09): please see upload

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/632064)

Final CD reflects estimated total monthly payment for payment stream 1 of $2,203.50.  Calculated amount is $2,202.08.

Reviewer Comment (2019-08-09): AMC received required documents, the exception is cured. Buyer Comment (2019-08-09): please see upload

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-09): Received lender's approval.

05/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Final CD reflects closing date of XXXX18.  Loan was consummated on XXXX18.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing evidence of rate lock.

Reviewer Comment (2019-08-09): Rec'd rate lock. Buyer Comment (2019-08-09): rate lock Reviewer Comment (2019-08-09): As of XXXXXX, still have not received the rate lock.

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

The final CD discloses the loan is not assumable, the note contains assumption language.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Missing valid change of circumstance for increased recording fees.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688261

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $425.00 exceeds tolerance of $375.00 plus 10% or $412.50.  Insufficient or no cure was provided to the borrower. (0)

Missing valid change of circumstance for increased recording fees.

Reviewer Comment (2019-08-09): AMC received required documents, the exception is cured. Buyer Comment (2019-08-09): please see final settlement statement.  Final recording fees total $357.00

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688262

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-09): Rec'd loan approval.

05/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688262

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Reviewer Comment (2019-08-09): Rec'd PDI, no damage. Buyer Comment (2019-08-09): dair

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688262

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Missing appraisal assignment letter from broker to lender.

Reviewer Comment (2019-08-09): Rec'd assignment letter.

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688262

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation disclosure not provided.

Reviewer Comment (2019-08-09): Attestation approved by AMC in file.

01/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688262

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees seller paid fees do not match Consumer's Final CD

TILA-RESPA Integrated Disclosure: the Seller's final CD total seller paid fee amounts do not match the values used for compliance testing. (Final/XXXXXX)

TRID non-compliant.  Seller paid fees on Seller CD are not consistent with those on Borrower Final CD.  Seller CD reflects $42,104.88 in seller paid fees.  Borrower Final CD reflects $13,186.88 in seller paid fees.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688262

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing evidence of rate lock.

Reviewer Comment (2019-08-09): Rec'd rate lock. Buyer Comment (2019-08-09): rate lock

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688262

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Waiver Less than 3 Days From Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Borrower provided appraisal waiver less than three (3) business days prior to consummation. (Type:Additional/XXXXXX)

Desk review waiver was signed XXXX18 which is after the consummation date.

Reviewer Comment (2019-08-09): Waive per client.

01/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688262

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

The final CD discloses the loan is not assumable, the note contains assumption language.

Reviewer Comment (2019-08-09): Waive as Note verbiage is correct in stating the loan is assumable and the CD is not accurate per client.

01/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688262

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

$150 appraisal reinspection fee.

Reviewer Comment (2019-08-09): Waive per client.

01/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688262

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (75103)

The appraisal is dated XXXX18 and is subject-to.  The addition of the appraisal reinspection fee on XXXX18 is not within 3 days of the change of circumstance.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): AMC received the invoice. As the appraisal was completed subject to prior to initial disclosure the information the fee was required was available. Please provide corrected CD, LOE, and refund check to cure. Buyer Comment (2019-08-09): the invoice was provided XXXXXX with the fee (the amount was not known until the invoice was received)

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender used higher income for borrower 3.

Borrowers on this Full Document documentation loan have a residual income of $5,016.83 which is greater than 3 x the VA residual income requirement of $990.00 for a family size of 3 in XXXXXX Housing history is clean for 69 months vs guideline minimum of 0 x 30 for 12 months.

Originator Originator

Reviewer Comment (2019-09-25): Lender approved exception to allow the final DTI of 54.89% with 2 verified compensating factors related to the borrower's ability to repay. Reviewer Comment (2019-09-23): Received verification of the monthly real estate taxes for the subject property, which results in a DTI of 54.89%. A lender approved exception with verified compensating factors related to the borrower's ability to repay is required to waive this exception. Reviewer Comment (2019-08-09): Client exception allows for a 55% DTI Buyer Comment (2019-08-09): see exception Buyer Comment (2019-08-09): actual property tax is $11,307.72 annual or $942.31 per month for XX (please see attached) Reviewer Comment (2019-08-09): XXXXXX income worksheet qualified the borrower with real estate taxes of $615.80. XXXXXX verifies monthly real estate taxes for the subject property are $1,263.83. In addition, the subject property was appraised as a PUD and the appraisal reported monthly HOA dues of $70.00 which were not included in the PITIA or the debt ratio calculation. Because the DTI of 57.82528% significantly exceeds the guideline maximum of 50.00%, this exception cannot be compensated to a lower grade. Reviewer Comment (2019-08-09): Total PITI $5219.83 (includes HOA not used by lender) and income + debts does put DTI at 57%. Buyer Comment (2019-08-09): XXXXXX income was qualified off the WVOE $27,545.51 / 10 = $2,754.55

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Reviewer Comment (2019-08-09): Updated policy with full iSOAMA provided.

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Verified document is not located in loan file.

Reviewer Comment (2019-08-09): Fraud guards provided and are acceptable.

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Credit Report: Original // Borrower: XXXXXX, Credit Report: Original // Borrower: XXXXXX, Credit Report: Original // Borrower: XXXXXX

Verified fraud report was not present in loan file.

Reviewer Comment (2019-08-09): Received full fraud report with all red flags addressed.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Verified LO Comp disclosure is not present in loan file.

Buyer Comment (2019-08-09): We have provided our broker agreement which shows that all transactions are based on a set compensation and not subject to terms of the transaction

04/02/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller Change - Total Payoffs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether there was a change in the Total Payoffs and Payments. (Final/XXXXXX)

The Final CD shows  a change in the amount of Payoffs/Payments - the variance is due to rounding.

Reviewer Comment (2019-09-23): AMC received PCCD correcting calculating cash to close table and LOE. Exception Cured. Reviewer Comment (2019-09-23): Re-open Reviewer Comment (2019-08-09): Okay to waive per client.

09/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

The Final CD shows the closing date to be XXXX18.  CD was signed by the borrowers as of XXXX18 which is less than three days from the disbursement date on XXXX18.

Reviewer Comment (2019-08-09): Closing statement provided shows disbursement date of XXXX18 Buyer Comment (2019-08-09): final settlement statement showing disbursement XX3 Reviewer Comment (2019-08-09): Our compliance department has reviewed this exception with this response: "Missing the documentary evidence that supports the disbursement actually took place on XXXXXX. If lender can provide the Final ALTA settlement statement or wire/funding worksheet prepared by the settlement agent to evidence the actual disbursement date as XXXXXX, we can use this date to clear the exception." Reviewer Comment (2019-08-09): This exception has been submitted to our compliance department for review. Buyer Comment (2019-08-09): the loan funded on XX30

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Verified the issue date was XXXX18, showing a closing date of XXXX18.  Borrowers signed XXXX18.

Reviewer Comment (2019-08-09): Waiving at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of $8,687.76 on Final Closing Disclosure provided on XXXXXX not accurate. (Final/XXXXXX)

Verified data input based on document in loan file.

Reviewer Comment (2019-09-23): AMC received PCCD correcting total property costs and LOE. Exception Cured. Reviewer Comment (2019-09-23): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): AMC received PCCD dated 1/XX19 with Estimated Taxes, Insurance & Assessments of $1,428.90 on page 1 and $17,146.80 on page 4.  The actual taxes are $7,612.99 semi-annually or $1,268.83/mo, HOI is $1,298.15 annually or $108.XXmo and HOA dues are $70/mo for a monthly total of $1,447.01 or  $17,346.12 annually.  A Corrected CD and LOE are required to cure.

09/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Guidelines show max DTI 55%.

Reviewer Comment (2019-09-23): Upon a rerun of compliance, this exception was cleared and a new DTI exception was issued. Reviewer Comment (2019-09-23): DTI is 57.83% and cannot be cleared with the lender exception uploaded on XXXXXX. Reviewer Comment (2019-08-09): Lender's guidelines allows for a 55% DTI w/ approved exception. Exception in file. Buyer Comment (2019-08-09): please see upload Reviewer Comment (2019-08-09): XXXXXX income worksheet qualified the borrower with real estate taxes of $615.80. XXXXXX verifies monthly real estate taxes for the subject property are $1,263.83. In addition, the subject property was appraised as a PUD and the appraisal reported monthly HOA dues of $70.00 which were not included in the PITIA or the debt ratio calculation. Because the DTI of 57.82528% significantly exceeds the guideline maximum of 50.00%, this exception cannot be compensated to a lower grade. Buyer Comment (2019-08-09): lenders income worksheet shows bdti of 51.24%.  please advise where the discrepancy is in your dti calculations so we can address. income worksheet attached.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Guidelines show max DTI 55%.

Reviewer Comment (2019-09-23): Upon a rerun of compliance, this exception was cleared and a new ATR Risk exception was issued. Reviewer Comment (2019-09-23): DTI is 57.83% and cannot be cleared with the lender exception uploaded on XXXXXX. Reviewer Comment (2019-08-09): Lender's guidelines allows for a 55% DTI w/ approved exception. Exception in file. Buyer Comment (2019-08-09): please see upload Reviewer Comment (2019-08-09): XXXXXX income worksheet qualified the borrower with real estate taxes of $615.80. XXXXXX verifies monthly real estate taxes for the subject property are $1,263.83. In addition, the subject property was appraised as a PUD and the appraisal reported monthly HOA dues of $70.00 which were not included in the PITIA or the debt ratio calculation. Because the DTI of 57.82528% significantly exceeds the guideline maximum of 50.00%, this exception cannot be compensated to a lower grade.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate Max Rate In Year

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on XXXXXX with an increasing rate disclosed the first date when the interest rate can reach the maximum that does not match the actual first date for the loan. (Final/XXXXXX)

Verified data input is accurate based on the final CD located in file.

Reviewer Comment (2019-09-23): AMC reviewed exception. Upon further review exception may be cleared. Reviewer Comment (2019-09-23): Re-open Reviewer Comment (2019-08-09): Letter of Explanation & Corrected Closing Disclosure provided.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Max Amount

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

Verified data input is accurate based on the final CD located in file.

Reviewer Comment (2019-09-23): AMC reviewed exception. Upon further review exception may be cleared. Reviewer Comment (2019-09-23): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Max Amount In Year

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

Verified data input is accurate based on the final CD located in file.

Reviewer Comment (2019-09-23): AMC reviewed exception. Upon further review exception may be cleared. Reviewer Comment (2019-09-23): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a maximum periodic principal and interest payment for payment stream 3 that does not match the actual maximum payment for the loan. (ProjSeq:3/653100)

Verified data input is accurate based on the final CD located in file.

Reviewer Comment (2019-09-23): AMC reviewed exception. Upon further review exception may be cleared. Reviewer Comment (2019-09-23): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a maximum periodic principal and interest payment for payment stream 4 that does not match the actual maximum payment for the loan. (ProjSeq:4/653101)

Verified data input is accurate based on the final CD located in file.

Reviewer Comment (2019-09-23): AMC reviewed exception. Upon further review exception may be cleared. Reviewer Comment (2019-09-23): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 57.82528% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

The Rate Sheet states DTI is 50% (55% on an exception basis)  - there is no exception information in the file.

Borrowers have  owned the subject property for 18 years Borrower has job stability for years as 16 years as a XXXXXX

Aggregator Aggregator

Reviewer Comment (2019-09-23): Upon a rerun of compliance, this exception was cleared and a new DTI exception was issued. Reviewer Comment (2019-09-23): DTI is 57.83% and cannot be cleared with the lender exception uploaded on XXXXXX. Reviewer Comment (2019-08-09): Compensating factors identified by client Buyer Comment (2019-08-09): please see upload Reviewer Comment (2019-08-09): Updated from: Ability to Repay (Dodd-Frank XX): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 57.82528% significantly exceeds the guideline maximum of 50.00%.  (DTI Exception cannot be compensated to a lower grade.)

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Note contains language stating loan is assumable.

Buyer Comment (2019-08-09): This was a system glitch and has now been fixed

04/02/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Unable to determine if the borrower signed a valuation receipt acknowledgment due to missing information. (Type:Secondary/XXXXXX)

Document missing to determine when valuation was provided to borrower.

Buyer Comment (2019-08-09): the email dated XX29 to the borrower with the appraisal attached is in the file

04/02/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 54.88925% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Updated tax cert received, changing DTI to 54.88% , down from the previosly cited DTI of 57.83%.

Borrowers have  owned the subject property for 18 years Borrower has job stability for years as 16 years as a XXXXXX

Aggregator Aggregator

Reviewer Comment (2019-09-23): Upon a rerun of compliance, this exception was cleared and a new DTI exception was issued. Reviewer Comment (2019-09-23): DTI is 57.83% and cannot be cleared with the lender exception uploaded on XXXXXX. Reviewer Comment (2019-08-09): Client provided compensating factors.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 57.66234% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

XXXXXX income worksheet qualified the borrower with real estate taxes of $615.80 and a DTI of 51.24%. However, the xxxx County Tax Bill verifies monthly real estate taxes for the subject property are $1,263.83. In addition, the subject property was appraised as a PUD and the appraisal reported monthly HOA dues of $70.00 which were not included in the PITIA or the debt ratio calculation. Because the DTI of 57.83% exceeds the guideline maximum by more than 5%, this exception  cannot be waived with the lender exception uploaded on XXXXXX or compensated to a lower grade.

Reviewer Comment (2019-09-24): Received a printout to verify county real estate taxes for the subject property are $942.31 monthly and proof the taxes bills were paid on XXXXXX and XXXXXX. This results in a DTI of 54.89%. Upon a rerun of compliance, this exception has been cleared.

09/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to a DTI of 54.89%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-25): Lender approved exception to allow the final DTI of 54.89% with 2 verified compensating factors related to the borrower's ability to repay. Reviewer Comment (2019-09-24): See comment in the DTI exceptions.

09/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 54.89%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-25): Lender approved exception to allow the final DTI of 54.89% with 2 verified compensating factors related to the borrower's ability to repay. Reviewer Comment (2019-09-24): See comment in the DTI exceptions.

09/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688264

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 54.88925% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Received verification of the monthly real estate taxes for the subject property, which results in a DTI of 54.89%.

Borrowers on this Full Document documentation loan have a residual income of $5,016.83 which is greater than 3 x the VA residual income requirement of $990.00 for a family size of 3 in XXXXXX Housing history is clean for 69 months vs guideline minimum of 0 x 30 for 12 months.

Originator Originator

Reviewer Comment (2019-09-25): Lender approved exception to allow the final DTI of 54.89% with 2 verified compensating factors related to the borrower's ability to repay. Reviewer Comment (2019-09-24): Received verification of the monthly real estate taxes for the subject property, which results in a DTI of 54.89%. A lender approved exception with verified compensating factors related to the borrower's ability to repay is required to waive this exception.

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688265

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Reviewer Comment (2019-08-09): Rec'd PDI, no damage noted.

05/20/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688265

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2019-08-09): Received Buyer Comment (2019-08-09): eoi exception and estimated replacement cost

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688265

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Hazard Insurance Policy Effective Date XXXXXX, Transaction disbursement date is XXXX18.

Reviewer Comment (2019-08-09): Rec'd final closing statement.  Coverage was in place at the time the loan funded on XXXX18. Buyer Comment (2019-08-09): loan disbursed on the xxth

05/10/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688265

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

Credit Report: Original // Borrower: XXXXXX

Reviewer Comment (2019-08-09): Rec'd fraud report. Buyer Comment (2019-08-09): fraudguard

05/10/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688265

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Credit Report Fee of $44.95 exceeds tolerance of $25.00.  No cure was provided to the borrower.

Reviewer Comment (2019-08-09): Waiving at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688265

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $44.95 exceeds tolerance of $25.00.  Insufficient or no cure was provided to the borrower. (7520)

Credit Report Fee of $44.95 exceeds tolerance of $25.00.  No cure was provided to the borrower.

Reviewer Comment (2019-08-09): New exception added for $20 broker credit fee. Buyer Comment (2019-08-09): the credit report fee for $25 was disclosed on the LE so the cure should be the $20 that was added for the broker credit report

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688265

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Final Closing Disclosure provided on XXXXXX disclosed a Closing Date  of XXXX18 that did not match the date of consummation XXXX18.

Reviewer Comment (2019-08-09): Waiving at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688265

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Re-Issue Fee.  Fee Amount of $20.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Cure required for the addition of the Broker Credit Fee of $20 on the Initial CD

Reviewer Comment (2019-08-09): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Buyer Comment (2019-08-09): cure , pccd, loe

07/23/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688266

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Property valuation variance is greater than 10% between the valuation report used for LTV and supporting valuation report.

Valuation Type: Appraisal / Valuation Report Date: XXXXXX

Lower value used to calculate LTV/CLTV ratios.

Reviewer Comment (2019-08-09): 2 full appraisals obtained at origination and lowest was used to determine LTV, exception may be cleared.

06/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Secondary/XXXXXX)

Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Secondary/XXXXXX)

Reviewer Comment (2019-08-09): Ok to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/XXXXXX)

Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing. (Type:Primary/XXXXXX)

Reviewer Comment (2019-08-09): Ok to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688266

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $7,800.00 on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

Amount of Non-Escrowed Property Costs over Year 1 of $9,240.00 on Final Closing Disclosure provided on XXXXXX not accurate

Reviewer Comment (2019-08-09): AMC received HOA invoice indicating HOA dues of $770/mo. Exception Cleared. Buyer Comment (2019-08-09): HOA documentation showing monthly amount of $770.00

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688267

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Hazard insurance amount of $xxxx (including additional coverage of $113,000.00) is not enough to cover the loan amount of XXXXXX or appraisal replacement cost of $xxxx. File is missing documentation from the property insurer to establish their opinion of the property's true replacement cost in order to determine if the amount of coverage is sufficient.

Reviewer Comment (2019-08-09): Received Buyer Comment (2019-08-09): please see uploads Reviewer Comment (2019-08-09): As of XXXXXX, still have not received a replacement cost estimator or updated insurance policy with coverage of at least $xxxx.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688267

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Most Recent Valuation Inspection Date: ___                  Disaster End Date: ___ Disaster Name: ___ Disaster Declaration Date: ___

Subject property was appraised on XXXXXX prior to the FEMA CA Wildfires disaster from XXXXXX through XXXXXX. A property inspection dated after the disaster is required to verify no damage to the subject property.

Reviewer Comment (2019-08-09): Received post-disaster inspection, which verifies no damage to the subject property in the last FEMA Disaster. Reviewer Comment (2019-08-09): Disaster inspection will be ordered by diligence vendor & exception updated upon receipt.

06/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688267

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provided.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

File is missing the Rate Lock Agreement.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688267

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 1/4/XX 12:00:00 AM was received.

Per DocMagic E-Sign Certification, the Revised Loan Estimate dated XXXXXX was signed and dated by the borrower on XXXXXX at 8:13 PM, which is prior to the Interim Closing Disclosure dated XXXXXX, which was signed and dated by the borrower on XXXXXX at 8:10 PM.

Reviewer Comment (2019-08-09): Cleared with compliance re-run.

05/07/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688267

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXXX not received by borrower at least four (4) business days prior to closing.

Loan Estimate dated XXXXXX was not received by the borrower at least 4 business days prior to the closing date of XXXXXX. File does not contain evidence of earlier borrower receipt or a written and signed statement from the borrower that waives the required waiting period.

Reviewer Comment (2019-08-09): Cleared with compliance re-run.

05/07/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688267

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Document Error: Bank statement financial institution not provided.

Per XXXXXX income worksheet, borrower was qualified with 24 months personal bank statements however, file only contains 16 months and is missing the following bank statements: March, XX; April, XX; May, XX; June XX; July, XX; August, XX; September, XX and January, XX. Upon receipt of the missing bank statements, additional conditions may apply.

59% LTV < 80 guideline max 744 representative FICO score > 680 guideline minimum

Originator Originator

Reviewer Comment (2019-10-24): Adding comp factors Buyer Comment (2019-08-09): please waive

05/10/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688267

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 17,179.80 on Final Closing Disclosure provided on XXXXXX not accurate.

Reviewer Comment (2019-08-09): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-08-09): pccd Buyer Comment (2019-08-09): exception and eoi replacement cost estimator

07/16/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688267

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller Change - Total Payoffs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether there was a change in the Total Payoffs and Payments.

Final Closing Disclosure Calculating Cash to Close Table disclosed Yes for Did this Change? for Total Payoffs and Payments (K) from -$xxxx to -$xxxx.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688267

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on XXXXXX disclosed a negative fee amount.

Final Closing Disclosure disclosed a negative amount of -$150.00 for borrower paid Title - Escrow Fee Coupon Credit in Section C. This is TRID non-compliant.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688267

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688268

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Missing Document: Rider - PUD not provided

Reviewer Comment (2019-08-09): Received Buyer Comment (2019-08-09): loan policy with PUD rider

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688268

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

The actual closing date is XXXXXX and the final CD closing date is reflected as XXXXXX.

Reviewer Comment (2019-08-09): Waiving at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688268

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Invalid changed circumstance in file, invoice received, for increased appraisal fee from $700.00 to $800.00. Refund of $100 due to the borrower.

Reviewer Comment (2019-08-09): Waiving at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688268

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $800.00 exceeds tolerance of $700.00.  Insufficient or no cure was provided to the borrower. (7506)

Invalid changed circumstance in file, invoice received, for increased appraisal fee from $700.00 to $800.00. Refund of $100 due to the borrower.

Reviewer Comment (2019-08-09): Additional documentation provided. borrower wanted to close ASAP appraisal rush was requested Buyer Comment (2019-08-09): Broker advised after initial le about increase to appraisal fee. Please see email attached.

07/17/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688268

XXXXXX

XXXXXX

Credit

Document Error

General

Property is a PUD.  PUD Rider was not indicated on the Security Instrument.

Reviewer Comment (2019-08-09): Received Buyer Comment (2019-08-09): please see upload

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688268

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Note is assumable and Closing Disclosure reflects loan is not assumable.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Right to Cancel was executed by the borrower on XXXXXX. The rescission period expiration was changed to XXXXXX with the change initialed by the borrower. However, Final Closing Disclosure disclosed a disbursement date of XXXXXX, providing the borrower with no rescission period.

Reviewer Comment (2019-08-09): Received the final settlement statement that verifies the loan was disbursed on XXXXXX. Buyer Comment (2019-08-09): final settlement statement showing funding xxx

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final Closing Disclosure disclosed a Closing Date of XXXXXX. Deed of Trust was notarized on XXXXXX.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller Change - Loan Amount

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether there was a change in Loan Amount.

Final Closing Disclosure Calculating Cash to Close Table disclosed No for Did this Change? for Loan Amount from $xxxx to $xxxx.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.

TRID non-compliant. Final Closing Disclosure, Section B disclosed the Lender as Payee for the Redraw Fee of $150.00. Payee must reflect the actual vendor in some manner (FBO, reimbursement to, etc).

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Good Faith Redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Re-Draw Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Re-Draw Fee was not disclosed on the Initial Loan Estimate dated XX17XX, but disclosed as $150.00 on the Final Closing Disclosure. Evidence of cure was not provided.

Reviewer Comment (2019-08-09): COC provided - docs had to be redrawn borrower requested loan program change Buyer Comment (2019-08-09): Redraw fee did not apply until CD with docs and was added due to the customers request to change loan terms after the initial docs were drawn.  Please see COC

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for 0% tolerance violation of $150.00 was not provided.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688269

XXXXXX

XXXXXX

Credit

System

General

Closing Disclosure Subject Address does not match Note address.

-

Note, Deed of Trust, Right to Cancel and tax certificate reflect the subject property address as XXXXXX , XXXXXX XXXXXX . The following documents reflect the subject address as XXXXXX , XXXXXX XXXXXX 4: Final CD, appraisal, preliminary title report, flood certificate, hazard insurance policy, mortgage payoff statement, fraud report and borrower's bank statements. The following documents reflect the subject address as XXXXXX , XXXXXX XXXXXX : Initial and Final 1003's (current address), loan estimate, and credit report. Based on the conflicting documentation provided, the subject property address cannot be verified.

Reviewer Comment (2019-08-09): Received a zip code look up that verifies the subject property has 2 different spelling of the street name (XXXXXX). All legal docs reflect XXXXXX Buyer Comment (2019-08-09): tax cert Buyer Comment (2019-08-09): recorded dot showing apn and min Buyer Comment (2019-08-09): per usps legal address is XXXXX

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - Bank Statements

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current employment status using reasonably reliable third-party records.

Borrower was qualified with business bank statement income. File only contains a printout of the business website and is missing verification of borrower's self-employment start date and ownership percentage of the business. Upon receipt of the start date and ownership percentage, additional conditions may apply.

Reviewer Comment (2019-08-09): Borrower was qualified using personal bank statements.  Documentation not required.

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Borrower was qualified with business bank statement income. File only contains a printout of the business website and is missing verification of borrower's self-employment start date and ownership percentage of the business. Upon receipt of the start date and ownership percentage, additional conditions may apply.

Reviewer Comment (2019-08-09): Borrower was qualified using personal bank statements.  Documentation not required.

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688269

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Subject loan designation is Non-QM however, loan does not meet the requirements of Non-QM due to missing verification of borrower's self-employment.

Reviewer Comment (2019-08-09): Underlying doc exceptions have been cleared, diligence designation is Non-QM Reviewer Comment (2019-08-09): Ok to waive per client.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Missing Lender's Approval with conditions.

Reviewer Comment (2019-08-09): Approval provided.

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

AUS Findings: All conditions were not met

The loan file does not contain documentation verifying the usability of the bank statement income for the co-borrower.

Reviewer Comment (2019-08-09): Updated information provided. Buyer Comment (2019-08-09): Loan is Non-QM therefore AUS will not be followed

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Documented qualifying Assets for Closing of  ___ is less than Cash From Borrower ___.

File is missing verification of $xxxx earnest money deposit.

Housing payment history clean for 12 months Borrower on this full documentation loan has a disposable income of $18,170 FICO score above minimum by 20 points or greater. FICO: 720 DTI below max by 5% or greater. DTI: 43.60%

Aggregator Aggregator Aggregator Aggregator

Reviewer Comment (2019-08-09): Client identified compensating factors Buyer Comment (2019-08-09): please see exception Reviewer Comment (2019-08-09): Updated commentary:  The $xxxx earnest money deposit was paid from unverified XXXXXX.  The account does not appear to belong to either borrower.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Documentation is missing from subject file.

Buyer Comment (2019-08-09): We have provided our broker agreement which shows that all transactions are based on a set compensation and not subject to terms of the transaction

04/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

All 1003's in file reflect the Originating LO's NMLS number as xxxx and NMLS reflects LO's NMLS number as xxxx.  The LO's license is active for this state and reflects a typographical error on 1003's.

Reviewer Comment (2019-08-09): Updated 1003's provided.

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Final Closing Disclosure dated XXXXXX disclosed a Closing Date of XXXXXX Deed of Trust was notarized on XXXXXX.

Buyer Comment (2019-08-09): XXXXXX closing documents are not date sensitive therefore it's ok if the borrower doesn't sign the date they're generated.

04/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $7,800.00 on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

Final Closing Disclosure dated XXXXXX disclosed Non Escrowed Property Costs Year 1 of $3,348.00; calculated maximum Estimated Total Monthly Payment is $30,495.00.  Lender did not calculate Property Tax Costs in Year 1.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): AMC received post close cd.  lender to provide tax calculation worksheet.  Unable to determine taxes calculated by lender

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

On Final CD under Total Closing Costs Exceeds Limits the amount is blank.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Unable to test disclosure of Home Loan Toolkit due to missing information.

Date of disclosure is missing from subject file.

Reviewer Comment (2019-08-09): Updated date provided. Reviewer Comment (2019-08-09): AMC received Initial Disclosure form line item 36 and 37 state handbook and toolkit,  document provided does not indict the date the items were sent Buyer Comment (2019-08-09): you can see on here that it was disclosed 9/XX18 with the initial disclosures

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

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

Date of disclosure is missing from subject file.

Reviewer Comment (2019-08-09): Updated information provided.

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application. (Initial/XXXXXX)

Evidence of earlier borrowers' receipt was not found in file.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): AMC confirms application date of XXXXXX. However, the only LE's in the file are dated XXXXXX and XXXXXX which is not within 3 business days of application date. Buyer Comment (2019-08-09): application date is 9/XXXX and the loan was disclosed 9/XXXX

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

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

Evidence of earlier borrowers' receipt was not found in file.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $3,800.59 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (7200)

Cure for various 0% tolerance violations of $4,006.79 was not provided.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): Disbursement date is not in question.  Lender needs to provide attestation on what the correct closing date should have been on the Final CD.  The Final CD has a closing date that is prior to the issue date. Buyer Comment (2019-08-09): this loan didn't fund until XX3/18 as shown on the final cd Reviewer Comment (2019-08-09): Unable to re-baseline fee since issue date of the final cd is XXXXXX with a closing date of XXXXXX.  Since closing date is prior to issue date attestation required to confirm what the correct closing date should have been on the final cd.  Please provide attestation to what the correct closing date should be on the Final CD. Reviewer Comment (2019-08-09): Unable to re-baseline fee since issue date of the final cd is XXXXXX with a closing date of XXXXXX.  Since closing date is prior to issue date attestation required to confirm what the correct closing date should have been on the final cd. Buyer Comment (2019-08-09): there was a .25% hit for waiving the taxes see attached

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $800.00 exceeds tolerance of $700.00.  Insufficient or no cure was provided to the borrower. (7506)

Cure for various 0% tolerance violations of $4,006.79 was not provided.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): Cure required to borrower.  Baseline amount of $700 used for appraisal fee.  Borrower charged $800.  Valid change of circumstance required to justify fee increase.  Per lender an estimate appraisal fee was used.  Lender held to baseline of $700 unless valid change of circumstance can be provided. Buyer Comment (2019-08-09): The appraisal XXXXXX is showing that it was charged to the borrower XXXXXX so that is within 3 days of the COC XXXXXX   Because we are not aware of the appraisal fee at time of disclosing a best estimate is used .. This is a valid change of circumstance based on section 1026.17(c)(2)(i) provides that if any information necessary for an accurate disclosure is unknown to the creditor, the creditor shall make the disclosure based on the best information reasonably available to the creditor at the time the disclosure is provided to the consumer. Reviewer Comment (2019-08-09): receipt of appraisal invoice with correct fee charged to the borrower not a valid change of circumstance.  lender should have been aware of the appraisal fee charges. loan estimate of $700 appraisal fee is binding and no new information was made available to justify fee increase Buyer Comment (2019-08-09): the invoices were not provided until the broker ordered the CD on the 19th there for an estimate was used for initial disclosure - actual fee were provided at the time of CD therefore the initial appraisal(s) fee was an estimate as the actual fee was not known at the time of disclosure. This is a valid change of circumstance based on section 1026.17(c)(2)(i) provides that if any information necessary for an accurate disclosure is unknown to the creditor, the creditor shall make the disclosure based on the best information reasonably available to the creditor at the time the disclosure is provided to the consumer.

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $800.00 exceeds tolerance of $700.00.  Insufficient or no cure was provided to the borrower. (7507)

Cure for various 0% tolerance violations of $4,006.79 was not provided.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXX exceeds tolerance of $2,383.00.  Insufficient or no cure was provided to the borrower. (8304)

Cure for various 0% tolerance violations of $4,006.79 was not provided.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): Addendum for loan amount increase is dated XXXXXX.  Loan Estimates in file confirm the lender was made aware of the increase at least on XXXXXX since the sales price is reflected as $xxx.  Transfer tax increase occurred on the Final CD issued XX29XX.  Borrower not notified of fee increase within 3 business days of lender being made aware of the changes. Buyer Comment (2019-08-09): sales price changed on XX3/18 as shown on uploaded addendum, previous sales price was $xxx Reviewer Comment (2019-08-09): AMC received sales contract addendum which confirms sales price of $xxx.  Unable to determine why transfer tax increased.  Sales price did not change. Reviewer Comment (2019-08-09): Sales price on final cd is the sane as the initial le of $xxxx unable to determine where sales price increased Buyer Comment (2019-08-09): escrow didn't provide the updated transfer tax based on the increased in sales price until the day that docs were drawn on XXXX18 .. see attached

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Reviewer Comment (2019-08-09): Upon rerun of compliance, exception was cleared.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 154.38681% significantly exceeds the guideline maximum of 50.00%.  (DTI Exception cannot be compensated to a lower grade.)

Reviewer Comment (2019-08-09): Updated to use income. Buyer Comment (2019-08-09): The co-borrowers income was not used … see attached that was in the file

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

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

Reviewer Comment (2019-08-09): ARM program chosen after loan application with appropriate change of circumstance. Buyer Comment (2019-08-09): this is the summary that shows you the initial disclosures and you can see the date on the form

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

The appraisal disclosure was provided on XXXXXX; however, the application date was XXXXXX.

Reviewer Comment (2019-08-09): Waiving at client request, EV2 Reviewer Comment (2019-08-09): AMC confirms application date of XXXXXX. However, the only LE's in the file are dated XXXXXX and XXXXXX which is not within 3 business days of application date. Buyer Comment (2019-08-09): this is in the file the AMC sent the report to the borrower

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

The servicing disclosure was provided on XXXXXX; however, the application date was XXXXXX.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

The List of Homeownership Counseling Organizations  was provided on XXXXXX; however, the application date was XXXXXX.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $475.00 exceeds tolerance of $375.00 plus 10% or $412.50.  Insufficient or no cure was provided to the borrower. (0)

Ten Percent Fee Tolerance exceeded.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD. (Final/XXXXXX)

The Seller's final CD reflected a real estate commission in the amount of $xxxx, which did not appear on the consumer's CD.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688271

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Per the final loan application, the co-borrower was the CEO of the disclosed company and bank statement income was used in the amount of $20,976.24 per month.  The loan file contained 24 months bank statements; however, the bank statements were in the borrower's name only.  There was no documentation in the loan file indicating that the co-borrower had any ownership interest in the bank account.  As a result of this, the co-borrower was not given any of the income on the bank statements.  Further, the Lender failed to include the monthly property tax amount of $2,707.37 in the debt ratio calculations.  As a result, the total debt ratio is 154.38681%.

Reviewer Comment (2019-08-09): Upon rerun of compliance, exception was cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688271

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Per the final loan application, the co-borrower was the xxx of the disclosed company and bank statement income was used in the amount of $20,976.24 per month.  The loan file contained 24 months bank statements; however, the bank statements were in the borrower's name only.  There was no documentation in the loan file indicating that the co-borrower had any ownership interest in the bank account.  As a result of this, the co-borrower was not given any of the income on the bank statements.  Further, the Lender failed to include the monthly property tax amount of $2,707.37 in the debt ratio calculations.  As a result, the total debt ratio is 154.38681%, which puts the loan at an ATR risk.

Reviewer Comment (2019-08-09): Upon rerun of compliance, exception was cleared.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Lenders loan approval was not located in loan package

Reviewer Comment (2019-08-09): Received lender's approval.

05/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Credit

Data Verification

General

The Investor's qualifying total debt ratio is less than the Non-QM qualifying total debt ratio.

Lender used a higher tax amount on 1008 than what is actual and what was used on closing disclosure

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

The loan office fee agreement was not found in the file, unable to determine what their fee is based on

Reviewer Comment (2019-08-09): Attestation approved by AMC in file.

01/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Verified per docs in file, directed to use Non QM designation

Reviewer Comment (2019-08-09): Upon further research, exception has been cancelled. Self-employed income has been recalculated and Final DTI of 49.88% is below the guideline maximum of 50%. Reviewer Comment (2019-08-09): This is a valid exception due to DTI > 50%. Reviewer Comment (2019-08-09): Upon further research, exception has been cancelled. Corrected ARM qualifying method.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

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

Clarity calculated TIP at 193.732 but CD shows it at 187.096

Reviewer Comment (2019-08-09): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

There was not amount provided on the closing disclosure

Reviewer Comment (2019-08-09): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Re-Issue Fee.  Fee Amount of $20.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (75117)

There was no valid change of circumstance provided for this fee increase shown on initial closing disclosure

Reviewer Comment (2019-08-09): AMC reviewed fee. Exception Cleared. Buyer Comment (2019-08-09): The Broker credit report of $20 was disclosed on the initial LE. This is erroneous.

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Entity Review Fee.  Fee Amount of $300.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (7543)

There was an additional fee added to initial closing disclosure and there was not valid change of circumstance provided to approve the fee change.

Reviewer Comment (2019-08-09): AMC reviewed fee. Exception Cleared. Buyer Comment (2019-08-09): The Entity review fee was on every LE. This is an erroneous.

05/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688273

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Application / Processing

Missing Document: Missing Lender's Initial 1003

No lender application or alternate credit source in file

Reviewer Comment (2019-08-09): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Missing Initial Loan Application Test

No evidence of application date located in file.  Compliance tests were run using an application date of XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.  The final date used for testing was XXXXXX

Unable to locate lenders 1003 or alternate credit source

Reviewer Comment (2019-08-09): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA NMLSR - Originator Company Not Licensed at time of Application

Unable to test LO company NMLS license due to missing information.

Unable to locate lenders 1003 or alternate credit source

Reviewer Comment (2019-08-09): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal Loan Originator Compensation - Individual LO Not NMLS Licensed at Time of Application

Unable to test Loan Originator license due to missing information.

Unable to locate lenders 1003 or alternate credit source

Reviewer Comment (2019-08-09): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA NMLSR - Individual Originator License Status Not Approved

Unable to test Individual Loan Originator license status due to missing information.

Unable to locate lenders 1003 or alternate credit source

Reviewer Comment (2019-08-09): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA NMLSR - Originator Company License Status Not Approved

Unable to test LO company status due to missing information.

Unable to locate lenders 1003 or alternate credit source

Reviewer Comment (2019-08-09): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.

Unable to locate lenders 1003 or alternate credit source

Reviewer Comment (2019-08-09): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Note allows assumption but CD indicates it does not

Reviewer Comment (2019-08-09): Waive per client.

01/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing

Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.

Unable to locate lenders 1003 or alternate credit source

Reviewer Comment (2019-08-09): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688273

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.

Unable to locate lenders 1003 or alternate credit source

Reviewer Comment (2019-08-09): Upon further research, exception has been cleared.

04/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688275

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 4,471.20 on Final Closing Disclosure provided on XXXXXX not accurate. (Final/XXXXXX)

Final CD reflects estimated property costs over year 1 of $4,471.20.  Calculated amount is $24,265.80 ($2,022.XXmo).  Variance is due to property taxes.  Subject is new construction and property taxes on title report appear to be raw land.  Used 1.25% of purchase price for review purposes.

Reviewer Comment (2019-08-09): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-08-09): pccd including hoa cost of $60 per month (per appraisal), 1.25% tax, $1444 eoi

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688275

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Guideline Requirement: Documented income duration  did not support the minimum guideline required duration.

Per CPA letter in file borrower has 42.5% ownership in XXXXXX which was incorporated on XXXXXX.  There are also references to attachments in CPA letter that are not in loan file.  Need proof borrower has been self-employed for minimum of 2 years, per guideline requirements.

29.33 months reserves > 12 months guideline minimum 34.96% DTI on this Bank Statement documentation loan < 50.00% guideline max - 15.04% below program guideline maximum Borrower has residual income of $27,698.26

Originator Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to waive the 2-year history of self-employment. Buyer Comment (2019-08-09): cpa letter mentions he has been  working with XXXXXX since XXXXXX and that it was aquired on  and incorporated as XXXXXXsince as of XXXXXX Reviewer Comment (2019-08-09): Disregarded, thanks Buyer Comment (2019-08-09): please disregard previous comment and upload, was for a different file Buyer Comment (2019-08-09): cpa letter states XXXXXX has been sole owner of XXXXXX since its inception.

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688275

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Loan is assumable when the initial fixed interest rate changes to an adjustable interest rate however CD indicates that loan is not assumable.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688275

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Amount Financed

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed an Amount Financed that was not within tolerance of the actual amount financed for the loan. (Final/XXXXXX)

,Amount on CD $xxxx vs calculated amount $xxxx

Reviewer Comment (2019-08-09): Cleared with compliance re-run.

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688275

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

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

Per CD calculated interest is 138.108% vs. calculated amount of 140.347%.

Reviewer Comment (2019-08-09): Cleared with compliance re-run.

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688275

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

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

Total payments on CD is $xxxx vs. calculated amount of $xxxx.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688275

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

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

Total payments on CD $xxxx vs. calculated amount of $xxxx.

Reviewer Comment (2019-08-09): Cleared with compliance re-run.

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688278

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Final approval was not provided.

Reviewer Comment (2019-08-09): Received

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688278

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Insurance policy effective date XXXX18, Note date XXXX18.

Reviewer Comment (2019-08-09): Final settlement statement shows disbursement on XX19. Buyer Comment (2019-08-09): loan funded on the xxth as evidence by the final settlement statement that is in the file

04/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Final CD reflects yearly HOA fee as $327 or $27.XXmonth. Appraisal reflects $XXmonth.

Reviewer Comment (2019-08-09): Updated HOA documents provided. Buyer Comment (2019-08-09): $327 is correct see attached

04/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $3,029.50 exceeds tolerance of $2,632.00 plus 10% or $2,895.20.  Insufficient or no cure was provided to the borrower.

Fees exceed 10% tolerance and no cure was provided.

Reviewer Comment (2019-09-30): Per e-mail from xxxx on XXXXXX: "Hi Ladies, The 10% tolerance violation of $134.30 is something we cannot cure on this file.  Please move the file forward to complete status.: Exception remains as an EV3. Reviewer Comment (2019-09-18): Per XXXXXX e-mail on XXXXXX: "Can you please review this one for us?  When I add up the escrow/title fees on final ss attached it looks like we are within tolerance ($2,895.20). Please let me know what figures you are using to come up with the $3029.50 if you are still seeing a tolerance violation please." This exception has been re-reviewed by our compliance department with this response: "Fees/services included in 10% tolerance are the fee lines and amounts below that total $3,029.50:" Section B: 04 Title - Closing Protection Letter Fee $25.00 05 Title - Closing/Escrow Fee $372.50 06 Title - Courier Fee $50.00 07 Title - Edoc Fee $75.00 08 Title - Endorsements Fee $400.00 09 Title - Lender's Title Insurance Fee $2,067.00 Section E: 01 Recording Fees $40.00 Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): AMC received final settlement statement. The fees in the 10% tolerance category are the amounts reflected on the final CD. The date of discovery is XXXXXX therefore exception is not able to be cured as date is more than 60 days prior. Buyer Comment (2019-08-09): please see final settlement statement. actual fees were lower and within tolerance Reviewer Comment (2019-08-09): If the fees were known by chosing the company on the settlement provider list, they should have been disclosed correctly from the binding LE or a valid COC was to be done. Buyer Comment (2019-08-09): when the initial disclosures were done the title fees were in section C as XXXXX hadn't received anything from them to know if they went with the preferred or their own. Once the loan was locked and escrow items were provided it was then they were moved to the didn't shop section as they used the preferred company

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Fees exceed 10% tolerance and no cure was provided.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688278

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD.

Consumer CD reflects $37,943.07, Seller CD reflects $37,944.07.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

207688278

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Missing Document: Asset Documentation not provided

Updated bank printouts for account XXXXXX and XXXXXX ending XXXX18 were not stamped/signed/dated by bank rep.

0 X 30 24 month housing history 80% LTV < 90% guideline max - FICO score above minimum by 20 points or greater - 762 vs program minimum of 660.

Aggregator Aggregator Aggregator

Reviewer Comment (2019-08-09): Waived with comp factors noted Buyer Comment (2019-08-09): exception Reviewer Comment (2019-08-09): These funds were needed for down payment, if other funds were utilized they were not provided in original loan package. Buyer Comment (2019-08-09): these were to show that the EMD cleared and not required to b stamped if the documentation can be verified

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688278

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Lender Exception(s) not provided

Self-employment income from Lockett International was used in qualifying however income used is not support by XX tax returns. Lender exception was not provided.

0 X 30 24 month housing history 80% LTV < 90% guideline max - FICO score above minimum by 20 points or greater - 762 vs program minimum of 660.

Aggregator Aggregator Aggregator

Reviewer Comment (2019-08-09): Exception provided by client for income used in qualifying.

04/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

207688280

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-09): Approval provided.

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207688280

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2019-08-09): Desk review provided. Buyer Comment (2019-08-09): this is in the file

04/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure XXXXXX 12:00:00 AM was received. (Interim/XXXXXX)

Loan Estimate default delivery date (since unsigned) is XXXXXX

Reviewer Comment (2019-09-27): While the rule and commentary in § 1026.19(e)(4)(ii) leave some room for interpretation as to what constitutes "provided", the final rule addresses the reasoning behind the requirement which is to prevent creditors from providing consumers with both estimates (LE) and actual costs (CD) at the same time. When the language in the rule and commentary leaves room for more than one interpretation, we look to the final rule that may provide more details and background related to the topic:    We have raised this issue more than once with outside counsel in the past year and they have consistently opined that they believe the testing of the revised LE receipt date vs. CD receipt date makes sense and is consistent with the regulation and commentary as a whole. Conceptually, this appears to be why there is the differential for the minimum timing for receipt of the disclosures prior to consummation; the consumer must receive the revised LE no later than 4 business days prior to consummation and the consumer must receive the CD no later than 3 business days prior to consummation - clearly indicating that the LE should be received prior to the CD; and as the final rule further explains above, on a different business day. Buyer Comment (2019-08-09): please waive

07/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

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

The closing date was XXXX18.

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-08-09): Please provide evidence of when the borrower received the LE issued XXXXXX.  AMC is currently using the mailbox rule which would have the received date of XXXXXX Buyer Comment (2019-08-09): Saturday is a business day.  loan is in compliance based on : day 1-XX24. day 2-XX26, day3 XX27, day 4 XX28

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD. (Final/XXXXXX)

$38,853.83 > $11,703.83

Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

Calculated amount is $556.64 vs. on CD it is $551.43.

Reviewer Comment (2019-09-27): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared. Reviewer Comment (2019-09-27): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (XXXXXX)

Projected amount showing on CD is $551.43 however calculated payments should be $556.64.

Reviewer Comment (2019-09-27): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared. Reviewer Comment (2019-09-27): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (XXXXXX)

Projected amount showing on CD is $551.43 however calculated payments should be $556.64.

Reviewer Comment (2019-09-27): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared. Reviewer Comment (2019-09-27): Reopening for further review. Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (XXXXXX)

Projected amount showing on CD is $551.43 however calculated payments should be $556.64.

Reviewer Comment (2019-09-27): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared. Reviewer Comment (2019-09-27): Reopening for further review. Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (XXXXXX)

Projected amount showing on CD is $551.43 however calculated payments should be $556.64.

Reviewer Comment (2019-09-27): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared. Reviewer Comment (2019-09-27): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/632064)

Projected amount showing on CD is $551.43 however calculated payments should be $556.64.

Reviewer Comment (2019-09-27): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared. Reviewer Comment (2019-09-27): Re-open Reviewer Comment (2019-08-09): 60 day window to cure has expired, per client moving to Waive as EV3

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

C

A

Non QM

Non QM

Yes

207688280

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

C

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Miscellaneous Credit (Non-Material):

Borrower lives and works in XXXXXX for 2 different companies.  No LOX on why she is currently renting out her primary residence or where she is currently living. No documentation that primary has no liens, taxes, insurance or HOA dues.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Miscellaneous Credit (Non-Material):

Missing currency conversions in file for assets and lease on primary. XXXXXX has $1335021.88 XXXXXX

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

For a foreign national borrower, we require the following:  YTD earnings and earnings for the last 2 years from employer on both jobs.

Per foreign employer letter, borrower has been employed at the company since XXXXXX 25.98 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow employer letters to verify the borrower's foreign employment and income. Buyer Comment (2019-08-09): exception

07/24/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Borrower does not have the minimum open tradelines per guidelines.

Foreign national loan requires 3 credit references with a 24 month history .  We have a copy of the borrowers list of references, but no actual reference letters.

Per foreign employer letter, borrower has been employed at the company since XXXXXX 25.98 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow only 1 credit reference for the foreign national borrower. Buyer Comment (2019-08-09): please see upload

07/24/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

DTI over 50% and no exception provided

Reviewer Comment (2019-08-09): Received the currency conversion from XXXXXX to US dollars to verify the monthly rent for the XXXXXX rental property. Buyer Comment (2019-08-09): Please see "Ability to Repay - REO" tab for response. Reviewer Comment (2019-08-09): See missing lease agreement exception. Buyer Comment (2019-08-09): exception Reviewer Comment (2019-08-09): Unable to waive. Reviewer Comment (2019-08-09): Ok to waive per client.

07/31/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - W-2

Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment status using reasonably reliable third-party records. (XXXXXX)

Employer letters on foreign national loan did not include YTD income or previous 2 years income.

Reviewer Comment (2019-08-09): Employer letter verifies borrower's start date, continued employment and annual income. Buyer Comment (2019-08-09): please see upload

07/24/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - W-2

Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment status using reasonably reliable third-party records. (XXXXXX)

Employer letters on foreign national loan did not include YTD income or previous 2 years income.

Reviewer Comment (2019-08-09): Employer letter verifies borrower's start date, continued employment and annual income. Buyer Comment (2019-08-09): please see upload

07/24/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - REO 25% Method

Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income (25% Method) using reasonably reliable third-party records. (Non-Subject Investment/25% Vacancy Method)

No documents provided to verify primary home is owned free and clear and has no insurance or taxes.

Reviewer Comment (2019-08-09): Received the currency conversion from XXXXXX to US dollars to verify the monthly rent for the XXXXXX rental property. Buyer Comment (2019-08-09): Note:  Conversion from XXXX to XXXX was done as of 7/26.    Current conversion rate is slightly higher than income figure used by underwriting. Buyer Comment (2019-08-09): The address of XXXXXX is the address for one of the borrower's references.    This may or may not be a relative of the borrower but it is not the borrower's husband who is named XXXXXX per Personal Information on Foreign Credit Report. Reviewer Comment (2019-08-09): Received borrower LOE for no taxes and insurance on a rental property in XXXXXX however, the property referenced in the letter is XXXXXX which does not match the rental property address disclosed on the Final 1003 of XXXXXX. In addition, the lease agreement provided reflects the monthly rent in XXXXXX and file is missing the translation into US dollars as required by XXXXXX Full Doc guidelines. Exception will remain until the translation of monthly rent into US dollars and borrower LOE with the correct property address is received. Buyer Comment (2019-08-09): loe

07/31/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Wages

Ability to Repay (Dodd-Frank 2014): Unable to verify Wages/W-2 income using reasonably reliable third-party records. (XXXXXX)

Employer letter did not provided YTD or previous years earnings.

Reviewer Comment (2019-08-09): Employer letter verifies borrower's start date, continued employment and annual income. Buyer Comment (2019-08-09): please see upload

07/24/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Wages

Ability to Repay (Dodd-Frank 2014): Unable to verify Wages/W-2 income using reasonably reliable third-party records. (XXXXXX)

Employer letter did not provided YTD or previous years earnings.

Reviewer Comment (2019-08-09): Employer letter verifies borrower's start date, continued employment and annual income. Buyer Comment (2019-08-09): please see upload

07/24/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

ATR fail due to missing employment information and DTI.

Reviewer Comment (2019-08-09): Received the currency conversion from XXXXXX to US dollars to verify the monthly rent for the XXXXXX rental property.

07/31/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Assumption language on the note.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Change - Deposit

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether there was a change in the Deposit. (Final/XXXXXX)

Deposit went from $0 to $49800 and box is marked No.

Reviewer Comment (2019-08-09): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688282

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

DTI exceeds 50% and no exception provided

Per foreign employer letter, borrower has been employed at the company since XXXXXX 25.98 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow a DTI up to 55% (subject loan DTI is 52.56%). Buyer Comment (2019-08-09): please see upload

07/24/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

ATR risk due to DTI over 50% with no exception.

Reviewer Comment (2019-08-09): Client approved exception to allow a DTI up to 55% (subject loan DTI is 52.56%). Buyer Comment (2019-08-09): please see upload

07/24/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.56361% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Missing information to accurate calculate DIT.

Per foreign employer letter, borrower has been employed at the company since XXXXXX 25.98 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow a DTI up to 55% (subject loan DTI is 52.56%). Buyer Comment (2019-08-09): please see upload

07/24/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate. (XXXXXX)

System generated should be $23,219.04 vs $24,031.56.

Reviewer Comment (2019-08-09): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared. Buyer Comment (2019-08-09): The CD is correct as the property taxes are $1,796.88 / month $21,562.56 / year and hazard is $205.75 / month $2,469 / year = $24,031.56

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan. (XXXXXX)

Actual monthly should be $1934.92 vs $2002.63

Reviewer Comment (2019-08-09): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared.

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan. (XXXXXX)

Actual monthly should be $1934.92 vs $2002.63

Reviewer Comment (2019-08-09): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared.

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan. (XXXXXX)

Actual monthly should be $1934.92 vs $2002.63

Reviewer Comment (2019-08-09): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared.

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan. (XXXXXX)

Actual monthly should be $1934.92 vs $2002.63

Reviewer Comment (2019-08-09): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared.

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688282

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. (ProjSeq:1/632064)

Actual monthly should be $1934.92 vs $2002.63

Reviewer Comment (2019-08-09): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared.

07/18/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688283

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Lenders loan approval was not located in loan file

Reviewer Comment (2019-08-09): Rec'd loan approval.

05/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Fraud report was not located in loan package

Reviewer Comment (2019-08-09): Rec'd fraud report. Buyer Comment (2019-08-09): FRAUDGUARD

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Primary/XXXXXX)

Date valuation was provided to applicant is prior to signature date on the appraisal.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.80130% or Final Disclosure APR of 6.71400% is in excess of allowable threshold of APOR 4.85% + 1.5%, or 6.35000%.  Non-Compliant Higher Priced Mortgage Loan.

Non Compliant Higher Priced Mortgage Loan, did not find a high cost analysis in loan file from lender

Buyer Comment (2019-08-09): please withdraw file. unable to clear Reviewer Comment (2019-08-09): Rec'd high cost analysis.  Exception due to under-disclosures and will remain EV3. Buyer Comment (2019-08-09): hpml test uploaded

3

C

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained prior to consummation.

Appraisal signature date is dated after the closing date. Evidence borrower received appraisal prior to closing which is entered and inventoried.

Reviewer Comment (2019-08-09): Rec'd original appraisal, dated XX4/18.  The appraisal dated XXXX18 had a minor correction to the parcel number. Buyer Comment (2019-08-09): initial disclosures dated 9/28, appraisal dated XX3

05/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provded.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

Lock date confirmation was not provided.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Qualification Method not Matching ATR

Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender does not match the ATR payment calculation methods under 1026.43(c)(5).

Used Non QM as directed

Reviewer Comment (2019-08-09): Cleared with compliance re-run

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

Initial escrow account statement does not match charges on HUD-1.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Amount Financed

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed an Amount Financed that was not within tolerance of the actual amount financed for the loan. (Final/XXXXXX)

Clarity calculated amount financed at xxxx, the CD however shows xxxx

Buyer Comment (2019-08-09): please withdraw file, unable to clear Reviewer Comment (2019-08-09): Updated commentary.  Used the lowest index value available during the look back period (2.83888%).  The CD reflects $xxx, whereas actual is xxx.

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

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

The finance charge is under disclosed by 17,244.55

Buyer Comment (2019-08-09): please withdraw file, unable to clear Reviewer Comment (2019-08-09): Updated commentary.  Used the lowest index value available during the look back period (2.83888%).  The CD reflects $xxx, whereas actual is $xxx.

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

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

Clarity calculated TIP at 131.647 and CD disclosed 127.253

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

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

Total of payments is under disclosed by 18,782.05

Buyer Comment (2019-08-09): please withdraw file, unable to clear Reviewer Comment (2019-08-09): Updated commentary.  Used the lowest index value available during the look back period (2.83888%).  The CD reflects $xxxx whereas actual is $xxxx

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

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

Borrower received 2 days prior to closing instead of 3

Buyer Comment (2019-08-09): please withdraw file, unable to clear

3

C

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Application / Processing

Missing Document: Missing Lender's Initial 1003

Did not locate lenders 1003 but did use an alternate credit source for app date

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

CD shows loan is not assumable the note however shows it is

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688283

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD. (Final/XXXXXX)

Most of the seller fees were obtained from the seller CD, not the consumers

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207688284

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-09): Received lender's approval.

05/08/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688284

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-08-09): Rec'd fraud report. Buyer Comment (2019-08-09): XXXX Date

05/10/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688284

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Reviewer Comment (2019-08-09): Rec'd PDI, no damage noted. Buyer Comment (2019-08-09): DAIR

05/16/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688284

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Calculated investor qualifying total debt ratio of 55.4484% exceeds Guideline total debt ratio of 50.00000%.  Funds required to close deducted from total asset balance.

Housing payment history clean for 38 months Borrower has residual income of $100,793.57 1,022.95 months reserves > 20 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow the final DTI of 51.20%. Reviewer Comment (2019-08-09): Attn XXXXXX: Please only provide ONE comment per exception. You do not have to comment each time a document is uploaded. When there are 5 duplicate comments, it makes it very difficult to follow. Thank you! As for this exception, sufficient documentation was provided to verify higher depletion income however, due to reserves having to be deducted, the verified depletion income only reduced to the DTI to 51.20%. This will require a client approved exception with verified compensating factors to allow a DTI above 50%. Buyer Comment (2019-08-09): The XXXXXX was formed as a single transaction limited liability for the subject property vesting. Buyer Comment (2019-08-09): Resulting DTI from attached asset calculation from $206,659 monthly asset depletion would be 45.08% and within guidelines.    Supporting documentation for comments on spreadsheet uploaded following. Reviewer Comment (2019-08-09): Per the income worksheet provided, borrower was qualified using $25,000,000.00 in assets and a monthly depletion income of $208,333.00 however, the bank and brokerage statements provided in the file verify total assets of $24,164,742.97. This does not include a deduction for required reserves of $249,622.22 for the subject second home (6 months) and 2 months each of additional reserves for the borrower's 4 financed properties. File contains a title company wire transfer receipt dated XXXXXX for closing funds of $673,206.15 however, these funds came from the account of XXXXXX. A 3 month checking account printout was provided for this company however, the printout does not verify sufficient funds to cover the wired amount of $673,206.15 and file is missing a 3rd party verification to verify the borrower is 100% owner of this business. Exception remains until verification of $25 million in total assets are provided. Buyer Comment (2019-08-09): please clarify calculations being used for asset depletion.  Per income worksheet we show over 25mm left for asset depletion after all deductions.  $25,989,780 assets -$123,000.00 emd -$671,274.37 (cash to close)-$167,720.00 reserves=$25,028,505.63

08/07/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing.

Reviewer Comment (2019-08-09): Attestation approved by AMC in file.

01/23/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Per Deal Notes.

Reviewer Comment (2019-08-09): Client approved exception to allow the final DTI of 51.20%. Buyer Comment (2019-08-09): Please see exception uploaded under "Investor Total Qualifying Debt Ratio Discrepancy" Tab. Reviewer Comment (2019-08-09): See comments under DTI exceptions. Buyer Comment (2019-08-09): Please see documents uploaded under "Investor Total Qualifying Debt Ratio Discrepancy" Tab. Reviewer Comment (2019-08-09): See comment in guideline DTI violation exception.

08/07/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI exceeds max due to deduction from total assets of closing funds required  to close.

Reviewer Comment (2019-08-09): Client approved exception to allow the final DTI of 51.20%. Buyer Comment (2019-08-09): Please see exception uploaded under "Investor Total Qualifying Debt Ratio Discrepancy" Tab. Reviewer Comment (2019-08-09): See comments under DTI exceptions. Buyer Comment (2019-08-09): Please see documents uploaded under "Investor Total Qualifying Debt Ratio Discrepancy" Tab. Reviewer Comment (2019-08-09): See comment in guideline DTI violation exception.

08/07/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of $67,477.44 on Final Closing Disclosure provided on XXXXXX not accurate. (Final/XXXXXX)

Amount of Estimated Property Costs over Year 1 of $67,477.44 on Final Closing Disclosure provided on XXXXXX not accurate.

Reviewer Comment (2019-08-09): Taxes used based on tax cert in the file

07/16/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Processing Fee.  Fee Amount of $225.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (77179)

Zero Percent Fee Tolerance exceeded for Title - Processing Fee. Fee Amount of $225.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-08-09): Fees paid to borrower chosen provider - no tolerance Buyer Comment (2019-08-09): borrower shopped so this doesn't apply

07/16/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements. (Type:Secondary/XXXXXX)

Reviewer Comment (2019-08-09): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 55.44840% significantly exceeds the guideline maximum of 50.00%.  (DTI Exception cannot be compensated to a lower grade.)

Reviewer Comment (2019-08-09): DTI is 54.36%.

05/09/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (77190)

Zero Percent Fee Tolerance exceeded.

Reviewer Comment (2019-08-09): Fees paid to borrower chosen provider - no tolerance Buyer Comment (2019-08-09): borrower shopped for title/escrow so this doesn't apply

07/16/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Admin Fee.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (77220)

Zero Percent fee tolerance exceeded.

Reviewer Comment (2019-08-09): Fees paid to borrower chosen provider - no tolerance Buyer Comment (2019-08-09): borrower shopped for title/escrow so this doesn't apply

07/16/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207688284

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 54.35586% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Housing payment history clean for 38 months Borrower has residual income of $100,793.57 1,022.95 months reserves > 20 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow the final DTI of 51.20%. Buyer Comment (2019-08-09): Please see exception uploaded under "Investor Total Qualifying Debt Ratio Discrepancy" Tab. Reviewer Comment (2019-08-09): Sufficient documentation was provided to verify higher depletion income however, due to reserves having to be deducted, the verified depletion income only reduced to the DTI to 51.20%. This will require a client approved exception with verified compensating factors to allow a DTI above 50%. Buyer Comment (2019-08-09): Please see documents uploaded under "Investor Total Qualifying Debt Ratio Discrepancy" Tab. Reviewer Comment (2019-08-09): See comment in guideline DTI violation exception.

08/07/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207688324

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD disclosed assumption is not allowed for this loan, however, Note contains assumption language and a non assumable rider was not provided.

Reviewer Comment (2019-08-09): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207688324

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final Closing Disclosure disclosed a Closing Date of XXXXXX. Deed of Trust was notarized on XXXXXX. Post-closing CD dated XXXXXX still disclosed the incorrect closing date of XXXXXX.

Buyer Comment (2019-08-09): please waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207688324

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 14,383.80 on Final Closing Disclosure provided on XXXXXX not accurate.

Final CD disclosed Amount of Estimated Property Costs over Year 1 of $14,383.80, however, the actual amount is $14,971.80.  Post-closing CD dated XXXXXX disclosed the correct amount of $14,971.80 however, file is missing the letter of explanation to the borrower required to cure.

Reviewer Comment (2019-08-09): Letter of Explanation & Corrected Closing Disclosure provided prior to AMC review. Buyer Comment (2019-08-09): pccd delivery

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207688325

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Flood Certificate not provided

Missing the Flood Certificate for the subject property.

Reviewer Comment (2019-08-09): Received the Flood Cert. Buyer Comment (2019-08-09): flood cert

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207688325

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provided.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

File is missing the Rate Lock confirmation.

Buyer Comment (2019-08-09): please waive

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207688325

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Guideline Requirement: Available for Reserves discrepancy.

Calculated Available for Reserves of ___ is less than Guideline Available for Reserves of ___.

Reserves after closing of $22,516.98 are insufficient to cover the total reserves required of $33,070.70 (subject PITI of $4,147.64 x 6 months = $24,885.84 + financed rental PITI of $4,092.43 x 2 months = $8,184.86).

Borrower on this Bank Statement documentation loan has a disposable income of $13,824.17 749 representative FICO score > 640 guideline minimum - 109 points above guideline minimum 40.63% DTI on this Bank Statement documentation loan < 50.00% guideline max - 9.37% below program guideline maximum

Originator Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow 4 months reserves after closing vs 6 months required. Buyer Comment (2019-08-09): exception

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207688326

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Fannie Mae 2014 - 3% Points and Fees

Fannie Mae 2014 3% Points and Fees Test.  Points and Fees on subject loan of XX% is in excess of the investor allowable maximum of  3.00000% of the Federal Total Loan Amount. Points and Fees total $XXXXX on a Federal Total Loan Amount of $XXXX vs. an investor allowable total of $XXXXX (an overage of $XXXX or .39884%).

Points and Fees for subject loan of 3.39884% exceed the 3.00% allowable maximum of the Federal total loan amount of $xxxx, and points and fees totaling $66,035.00 exceed the allowable maximum of $58,286.10, which is an overage of $7,748.90 or .39884%.

Buyer Comment (2019-08-09): please waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207688326

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD disclosed loan does not allow Assumption, however, Note contains assumption language.

Reviewer Comment (2019-08-09): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207688326

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___

File is missing the Verbal VOE dated within 10 days of closing from the borrower's current employer.

Reviewer Comment (2019-08-09): Received

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207688327

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provided.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

File is missing the Rate Lock confirmation.

Buyer Comment (2019-08-09): please waive

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207688327

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note contains assumption verbiage in section 11B.  The Borrower's final Closing Disclosure reflects assumption is not allowed and A Non Assumability Addendum is missing.

Reviewer Comment (2019-08-09): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207688327

XXXXXX

XXXXXX

Credit

Income

Document Error

Bank Statements were used for income. All parties listed on each bank account must be included as borrowers on the loan per company guidelines.

Borrower was qualified with personal bank statement income. Bank statements are held jointly in the name of the borrower and another person however, the joint account owner is not a borrower on the loan as required by XXXXXX Bank Statement guidelines. File is missing a lender exception with compensating factors to allow the sole borrower to use jointly owned personal bank statements.

Housing payment history clean for 48 months vs 12 months guideline requirement 791 representative FICO score > 640 guideline minimum - 141 points above guideline minimum 39.22% DTI on this Bank Statement documentation loan < 50.00% guideline max - 10.78% below program guideline maximum

Originator Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow jointly owned personal bank statements to be used for personal bank statement income for the sole borrower.

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207688328

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note contains Assumption verbiage in Section 11B, but the Borrower's final Closing Disclosure reflects assumption is not allowed and a Non Assumability Rider is missing.

Reviewer Comment (2019-08-09): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207688328

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

The Borrower's Closing Disclosure reflects Seller paid fees.  However, a Seller's Closing Disclosure is missing.

Buyer Comment (2019-08-09): please waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207688328

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___

File is missing the wage earner borrower's most recent W-2 as required by XXXXXX Full Doc guidelines.

Reviewer Comment (2019-08-09): Received Buyer Comment (2019-08-09): ots  XX w2

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207688329

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD disclosed loan does not allow assumption, however, Note contains assumption language.

Reviewer Comment (2019-08-09): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207688329

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

XXXXXX Full Doc guidelines require a maximum LTV of 80% for Non-Occupant Co-borrowers. Subject loan with Non-Occupant Co-borrowers closed with an LTV of 85% and file is missing the lender's approved exception with compensating factors to allow the higher LTV.

Borrowers have residual income of $1,227,871.44 13.06% DTI on this Full documentation loan < 50% guideline max - 36.94% below program guideline maximum

Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow an LTV of 85% for a Non-Occupant Co-borrower loan.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207688329

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Guideline Requirement: Available for Reserves discrepancy.

Calculated Available for Reserves of ___ is less than Guideline Available for Reserves of ___.

Verified reserves after closing of $26,514.16 are insufficient to cover the required reserves of $239,549.72 for 12 months PITI for the subject property with a loan amount above $1,500,000.01 and three other financed properties. File is missing verification that the $xxxx EMD came from the borrowers own funds. In addition, file contains XXXXXX brokerage account statements in the name of the non-borrowing spouse of the non-occupant co-borrower and file is missing verification from XXXX that the non-occupant co-borrower has unrestricted access to these funds.

Borrowers have residual income of $1,227,871.44 13.06% DTI on this Full documentation loan < 50% guideline max - 36.94% below program guideline maximum

Originator Originator

Reviewer Comment (2019-08-09): Client approved exception to allow the non-borrowing spouse's account to be used to cover the subject loan's required reserves. Reviewer Comment (2019-08-09): Per XXXXXX Underwriting guidelines: "Asset documentation must clearly identify the borrower as the account holder." The non-borrowing spouse on title only is NOT considered a borrower. If XXXXXX wants to allow this account, a client approved exception with verified compensating factors that clearly states the non-borrowing spouse's account is allowed to be used for reserves is required to waive this exception. Buyer Comment (2019-08-09): We use the non-occupying co borrower's spouses assets because even though she is not on the loan she was going on TITLE and therefore has a vested interest in the transaction.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207688330

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

There are Seller paid fees reflected on the Borrower's final Closing Disclosure.  However, the Seller's Closing Disclosure is missing.

Buyer Comment (2019-08-09): please waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688330

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note contains Assumption verbiage in section 11B.  A Non Assumability Addendum was not included.  Page 4 of final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-08-09): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688330

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower was qualified with monthly debts of $6,356.10 and a DTI of 42.72%. Verified debts, including property expense payments for 3 rental properties, results in monthly debts of $9,247.85 and a DTI of 53.81%, which exceeds the XXXXXX guideline maximum of 50%.

Reviewer Comment (2019-08-09): Received XX tax return to verify Schedule E rental income. Buyer Comment (2019-08-09): Per Income Calculation Analysis, rental properties show $1006.05 positive cash flow (XXXXXX).   XXXXXX is owned by non-borrowing spouse.  XXXXXX is not reported on 1040s and has been added to liabilities.   Underwriter ratios 26.62/47.06%.

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688330

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 53.80714% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower was qualified with monthly debts of $6,356.10 and a DTI of 42.72%. Verified debts, including property expense payments for 3 rental properties, results in monthly debts of $9,247.85 and a DTI of 53.81%, which exceeds the XXXXXX guideline maximum of 50%.

Reviewer Comment (2019-08-09): Received XX tax return to verify Schedule E rental income. Buyer Comment (2019-08-09): Please see response under "Investor qualifying total debt ratio discrepancy".

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688330

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to a DTI of 53.81%, the subject loan is at ATR Risk.

Reviewer Comment (2019-08-09): Received XX tax return to verify Schedule E rental income. Buyer Comment (2019-08-09): Please see response under "Investor qualifying total debt ratio discrepancy".

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207688330

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 53.81%, the subject loan is at ATR Risk.

Reviewer Comment (2019-08-09): Received XX tax return to verify Schedule E rental income. Buyer Comment (2019-08-09): Please see response under "Investor qualifying total debt ratio discrepancy".

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207688345

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note contains assumption verbiage and a Non Assumability Addendum is missing.  The final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-08-09): Waive per client request.

07/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207688345

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final Closing Disclosure disclosed a Closing Date of XXXXXX. Deed of Trust was notarized on XXXXXX.

Reviewer Comment (2019-08-09): Exception was previously waived.  No additional comments or documents are needed. Buyer Comment (2019-08-09): please update dillilgence status to complete so this file can move forward Reviewer Comment (2019-08-09): Exception addressed previously. Buyer Comment (2019-08-09): please update file status to complete.  no open conditions but still shows as "in exception clearing Reviewer Comment (2019-08-09): Waive per client request.

07/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207764039

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Right to Cancel was executed by the borrower on XXXXXX. The document date was changed to XXXXXX and the rescission period expiration was changed to XXXXXX with the changes initialed by the borrower. However, the Final Closing Disclosure disclosed a disbursement date of XXXXXX, providing the borrower with no rescission period.

Reviewer Comment (2019-08-19): Received certified final settlement statement that verifies the final disbursement date of XXXXXX. Buyer Comment (2019-08-19): final settlement statement attached showing disbursement 5/28 Reviewer Comment (2019-08-19): Received a final settlement statement that did not disclose the actual  disbursement date which is required to clear this exception.

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764039

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD disclosed loan does not allow assumption, however, Note contains assumption language

Reviewer Comment (2019-08-19): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764039

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final Closing Disclosure disclosed a Closing Date of XXXXXX. Deed of Trust was notarized on XXXXXX.

Buyer Comment (2019-08-19): please waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764039

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Total cash-out discrepancy.

HUD-1 total cash-out of ___ is greater than Guideline total cash-out of ___.

Total cash out of $888,539.93 exceeds the XXXXXX Full Doc guideline maximum cash-out of $500,000.00.

Borrower has a disposable income of $16,954 Borrower has employment stability for 18 years

Originator Originator

Reviewer Comment (2019-08-19): Waived with comp factors noted

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764039

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrower was qualified with a P&I payment of $8,541.67 for the subject 10-year interest only ARM and a DTI of 37.408%. XXXXXX Guidelines and ATR Rules require the loan to be qualified at the fully amortized payment at the greater of the fully indexed or the note rate, to repay the loan over the remaining term after the I/O period. Qualifying P&I payment is $9,988.03 resulting in a DTI of 50.27%, which exceeds XXXXXX Guideline maximum of 50%. A lender approved exception with compensating factors for a DTI above 50% is required to waive this exception.

Borrower has a disposable income of $16,954 Borrower has employment stability for 18 years

Originator Originator

Reviewer Comment (2019-08-19): Waived with comp factors noted

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764039

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 50.27103% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower was qualified with a P&I payment of $8,541.67 for the subject 10-year interest only ARM and a DTI of 37.408%. XXXXXX Guidelines and ATR Rules require the loan to be qualified at the fully amortized payment at the greater of the fully indexed or the note rate, to repay the loan over the remaining term after the I/O period. Qualifying P&I payment is $9,988.03 resulting in a DTI of 50.27%, which exceeds XXXXXX Guideline maximum of 50%. A lender approved exception with compensating factors for a DTI above 50% is required to waive this exception.

Borrower has a disposable income of $16,954 Borrower has employment stability for 18 years

Originator Originator

Reviewer Comment (2019-08-19): Waived with comp factors noted

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764039

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to a DTI of 50.27%, the subject loan is at ATR Risk.

Reviewer Comment (2019-08-19): Cleared with DTI waiver received

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764039

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 50.27%, the subject loan is at ATR Risk.

Reviewer Comment (2019-08-19): Cleared with DTI waiver received

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764040

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Guidelines require a 24 month P & L, did not find in file

Reviewer Comment (2019-08-19): Received P&L Statements dated from XXXXXX through XXXXXX. Buyer Comment (2019-08-19): p&L

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764040

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Did not locate fraud report in loan package

Reviewer Comment (2019-08-19): Rec'd fraud report. Buyer Comment (2019-08-19): fg uploaded

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764040

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

-

Duplicate exception, fraud report not found in file

Reviewer Comment (2019-08-19): Rec'd fraud report. Buyer Comment (2019-08-19): fg uploaded

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final Closing Disclosure reflects this loan is not Assumable, however the Note indicates it is.

Reviewer Comment (2019-08-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

The Final Closing Disclosure reflects $6894 of Non-Escrowed Property Costs over Year 1, or $574.5 monthly. Monthly HOA dues are $685 or $8220 over a year.

Reviewer Comment (2019-08-19): AMC received PCCD correcting non escrowed property costs and LOE. Exception Cured. Buyer Comment (2019-08-19): pccd

07/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

The Final Closing  Disclosure reflects a Total Interest Percentage of 129.185%.

Reviewer Comment (2019-08-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total of Payments that does not match the actual total of payments for the loan.

The Final Closing  Disclosure reflects Total of Payments of $xxxx.

Reviewer Comment (2019-08-19): Cleared with compliance re-run.

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Amount Financed

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed an Amount Financed that was not within tolerance of the actual amount financed for the loan.

Amount financed is under disclosed by $1,845.00

Reviewer Comment (2019-08-19): Cleared with compliance re-run.

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charge is under disclosed by $5,072.39

Reviewer Comment (2019-08-19): Cleared with compliance re-run.

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764040

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Received P&L Statements dated from XXXXXX through XXXXXX that verify a 24-month average income of $5,798.46. Borrower was qualified with the higher income disclosed on the Initial 1003 of $11,767.07 however, XXXXXX Bank Statement guidelines require the lower of the P&L average or the income disclosed on the Initial 1003. Using the lower P&L income results in a DTI of 84.17% which cannot be waived.

Housing payment history clean for 43 months Borrower has residual income of $7,020.24 21.89 months reserves > 6 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-08-19): Client approved exception to allow the use of 24-month business bank statement average, which is not supported by the year-to-date P&L statement for the same time period. DTI is now 41.01%. Buyer Comment (2019-08-19): exception Reviewer Comment (2019-08-19): Please review the P&L statements (24 months total) for the borrower's company, XXXXXX and compare to the income worksheet. The lender's 24-month average is incorrect. Lender's calculation of $60,672.00 + $66,156.00 / 24 months = $5,284.50, not $11,537.29 as noted on the worksheet. P&L calculations are as follows: P&L #1 dated XXXXXX through XXXXXX disclosed a 12-month annual net income of $72,266.00. P&L #2 dated XXXXXX through XXXXXX disclosed a 12-month annual net income of $66,897.00. $72,266.00 + $66,897.00 = $139,163.00 / 24 months = $5,798.46. Business bank statements verify a 24-month average income of $11,900.78, which is not supported by the P&L statements as required by the guidelines. If XXXXXX is using the bank statement average, this exception will required a client approved exception with verified compensating factors to allow the use of the higher bank statement average that is not supported by the P&L statements. Buyer Comment (2019-08-19): lenders income calc shows 11,314.02 average income

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 84.16959% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Received P&L Statements dated from XXXXXX through XXXXXX that verify a 24-month average income of $5,798.46. Borrower was qualified with the higher income disclosed on the Initial 1003 of $11,767.07 however, XXXXXX Bank Statement guidelines require the lower of the P&L average or the income disclosed on the Initial 1003. Using the lower P&L income results in a DTI of 84.17% which cannot be waived.

Reviewer Comment (2019-08-19): Client approved exception to allow the use of 24-month business bank statement average, which is not supported by the year-to-date P&L statement for the same time period. DTI is now 41.01%. Buyer Comment (2019-08-19): please see uploaded exception to use bank statement income Reviewer Comment (2019-08-19): Please review the P&L statements (24 months total) for the borrower's company, XXXXXX and compare to the income worksheet. The lender's 24-month average is incorrect. Lender's calculation of $60,672.00 + $66,156.00 / 24 months = $5,284.50, not $11,537.29 as noted on the worksheet. P&L calculations are as follows: P&L #1 dated XXXXXX through XXXXXX disclosed a 12-month annual net income of $72,266.00. P&L #2 dated XXXXXX through XXXXXX disclosed a 12-month annual net income of $66,897.00. $72,266.00 + $66,897.00 = $139,163.00 / 24 months = $5,798.46. Exception remains. Buyer Comment (2019-08-19): our income calculation shows 24 mo average of 11,314.02. please relcuate or advise how $5,798 is being calculated by AMC.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to a DTI of 84.17%, the subject loan is at ATR Risk.

Reviewer Comment (2019-08-19): Client approved exception to allow the use of 24-month business bank statement average, which is not supported by the year-to-date P&L statement for the same time period. DTI is now 41.01%. Buyer Comment (2019-08-19): see upload Reviewer Comment (2019-08-19): See comment and income calculations in DTI exceptions. Buyer Comment (2019-08-19): please see income calc uploaded

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764040

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 84.17%, the subject loan is at ATR Risk.

Reviewer Comment (2019-08-19): Client approved exception to allow the use of 24-month business bank statement average, which is not supported by the year-to-date P&L statement for the same time period. DTI is now 41.01%. Buyer Comment (2019-08-19): see upload Reviewer Comment (2019-08-19): See comment and income calculations in DTI exceptions. Buyer Comment (2019-08-19): please see income calc uploaded

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

The appraisal waiver was signed by borrower XXXXXX and there was no evidence of appraisal delivery in file, only signed receipt which does not work if a waiver is signed

Reviewer Comment (2019-08-19): Ok to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207764041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

The appraisal waiver was signed by borrower XXXXXX.

Reviewer Comment (2019-08-19): Ok to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207764041

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

AVM used as supporting valuation contains an FSD that is blank or is greater than 20%.

-

Information was not provided.

Reviewer Comment (2019-08-19): Rec'd CDA

05/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207764041

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender did not include borrowers mortgage payment on current primary home not yet sold

75.89 months reserves > 6 months guideline minimum Borrower has residual income of $7,746.90

Originator Originator

Reviewer Comment (2019-08-19): Client approved exception to exclude the departing residence payment from the DTI without the listing agreement as required by XXXXXX guidelines. DTI is now 49.68%. Buyer Comment (2019-08-19): please see upload Reviewer Comment (2019-08-19): Received the loan terms for the bridge loan on the borrower's departure residence, which verifies an interest-only payment of $XXXX. Including taxes, insurance and HOA expenses, the DTI remains at  59.65% and cannot be waived. Per XXXXXX underwriting guidelines, "If the current primary residence is listed for sale but not sold, the payment can be excluded from the DTI calculation with the following: Copy of current listing agreement as well as an additional 6 months of the listed property's underlying principal, interest, taxes, and insurance ("PITI") cash reserves (over and above loan program reserve requirements)." Borrowers have sufficient reserves however, the listing agreement was not provided and is required to reduce the DTI to 46.75% and clear this exception. Without the listing agreement or proof the departure residence has been sold, the exception will remain. Buyer Comment (2019-08-19): bridge loan terms Reviewer Comment (2019-08-19): Missing repayment terms for bridge loan.  Documentation in file reflects "interest only" but does not provide a term.  Upon receipt of bridge loan terms, DTI may be within guidelines.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207764041

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

AUS Findings: All conditions were not met

Lender did not include borrowers mortgage payment on current primary home not yet sold

Reviewer Comment (2019-08-19): Not AUS

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207764041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Primary home, used non qm as directed

Reviewer Comment (2019-08-19): Client approved exception to exclude the departing residence payment from the DTI without the listing agreement as required by XXXXXX guidelines. DTI is now 49.68%. Reviewer Comment (2019-08-19): Received the loan terms for the bridge loan on the borrower's departure residence, which verifies an interest-only payment of $1,531.25. Including taxes, insurance and HOA expenses, the DTI remains at  59.65% and cannot be waived. Per XXXXXX underwriting guidelines, "If the current primary residence is listed for sale but not sold, the payment can be excluded from the DTI calculation with the following: Copy of current listing agreement as well as an additional 6 months of the listed property's underlying principal, interest, taxes, and insurance ("PITI") cash reserves (over and above loan program reserve requirements)." Borrowers have sufficient reserves however, the listing agreement was not provided and is required to reduce the DTI to 46.75% and clear this exception. Without the listing agreement or proof the departure residence has been sold, the exception will remain. Buyer Comment (2019-08-19): please see upload

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207764041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI is exceeded because of current primary home not sold yet

Reviewer Comment (2019-08-19): Client approved exception to exclude the departing residence payment from the DTI without the listing agreement as required by XXXXXX guidelines. DTI is now 49.68%. Buyer Comment (2019-08-19): exception Reviewer Comment (2019-08-19): Received the loan terms for the bridge loan on the borrower's departure residence, which verifies an interest-only payment of $XXXX. Including taxes, insurance and HOA expenses, the DTI remains at  59.65% and cannot be waived. Per XXXXXX underwriting guidelines, "If the current primary residence is listed for sale but not sold, the payment can be excluded from the DTI calculation with the following: Copy of current listing agreement as well as an additional 6 months of the listed property's underlying principal, interest, taxes, and insurance ("PITI") cash reserves (over and above loan program reserve requirements)." Borrowers have sufficient reserves however, the listing agreement was not provided and is required to reduce the DTI to 46.75% and clear this exception. Without the listing agreement or proof the departure residence has been sold, the exception will remain. Buyer Comment (2019-08-19): XXXX printout Buyer Comment (2019-08-19): 1003 shows XXXXXX was to be listed for sale.  Also rent per XXXX shows $XXXX and covers payment.

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207764041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

CD shows will not allow assumption but note contains assumption

Reviewer Comment (2019-08-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207764041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

CD shows 125.191 clarity calculated 123.011

Reviewer Comment (2019-08-19): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207764041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 9,973.32 on Final Closing Disclosure provided on XXXXXX not accurate.

Home insurance is a few dollars higher than what lender showed

Reviewer Comment (2019-08-19): AMC received HOI policy reflecting $1804 / year for premium Buyer Comment (2019-08-19): please see final cd and supporting documentation . subsequent eoi  attached Reviewer Comment (2019-08-19): Final Closing Disclosure disclosed Estimated Property Costs over Year 1 of $9,973.32. Estimated Property Costs are $835.78 per month, which equates to calculated Escrowed Property Costs over Year 1 of $10,029.36. Difference is due to Hazard Insurance Policy reflects an annual premium of $1,860.00 however, the Final Closing Disclosure, Section F. Prepaids disclosed the annual Homeowner's Insurance Premium as $1,804.00. As of XXXXXX, still have not received the Letter of Explanation to the borrower and Corrected Closing Disclosure required to cure this exception.

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207764041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 59.65479% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Received the loan terms for the bridge loan on the borrower's departure residence, which verifies an interest-only payment of $1,531.25. Including taxes, insurance and HOA expenses, the DTI remains at  59.65% and cannot be waived. Per XXXXXX underwriting guidelines, "If the current primary residence is listed for sale but not sold, the payment can be excluded from the DTI calculation with the following: Copy of current listing agreement as well as an additional 6 months of the listed property's underlying principal, interest, taxes, and insurance ("PITI") cash reserves (over and above loan program reserve requirements)." Borrowers have sufficient reserves however, the listing agreement was not provided and is required to reduce the DTI to 46.75% and clear this exception. Without the listing agreement or proof the departure residence has been sold, the exception will remain.

75.89 months reserves > 6 months guideline minimum Borrower has residual income of $7,746.90

Originator Originator

Reviewer Comment (2019-08-19): Client approved exception to exclude the departing residence payment from the DTI without the listing agreement as required by XXXXXX guidelines. DTI is now 49.68%. Buyer Comment (2019-08-19): please see upload

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

Missing 12 month mortgage rating for XXXXXX.  Credit sup reflects XXXXXX.  Missing prior rating.

Reviewer Comment (2019-08-19): Rec'd mortgage statements for both properties.  XXXXXX rated on credit, XXXXXX rated via bank printout / cancelled check(s). Reviewer Comment (2019-08-19): Mortgage statement provided in file for XXXXXX is from XXXXXX and reflects a balance of xxxx. Missing mortgage history for this mortgage. Missing mortgage statement from XXXXXX to match up with XXXXXX to confirm mortgage history reflected on credit report. Buyer Comment (2019-08-19): the VOM for SLS was for the loan just originated in 2/XX - the borrower complete housing history is on their credit report with XXXXXX

05/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-19): Rec'd loan approval. Buyer Comment (2019-08-19): approval for roitz Reviewer Comment (2019-08-19): Received copy of an approval for a different property., XXXXXX. Still missing for subject property, XXXXXX Buyer Comment (2019-08-19): the VOM for SLS was for the loan just originated in 2/XX - the borrower complete housing history is on their credit report with XXXX

05/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Issue appears to be due to using incorrect qualifying method on Note.  Guidelines state Interest only qualification is the greater of the note rate or the fully indexed rate (margin + index) amortized over 30 years is used to qualify. The interest only period is the initial 10 years followed by a 30 year amortized period.  Note in file reflects 10 year IO followed by a 20 year amortized period.

17.33 months PITIA reserves vs guideline required 12 months. Borrower has $598,245.92 assets for reserves after closing Mortgage history 0 x 30, 95 months on credit report.

Originator Originator

Reviewer Comment (2019-08-19): Finally received the lender approved exception to allow the borrower to be qualified with the P&L statement averages only. Lender also finally provided the documented rationale on the XXXXXX letterhead for using the P&L statements for the self-employed borrower's income and matching income worksheet. Reviewer Comment (2019-08-19): Received an unsigned and undated rationale paper (that is not on company letterhead) to explain the income calculations. However, in order to provide the investor with acceptable documentation should the borrower's ability to repay ever be questioned, the following is required to revise the income to an 18-month P&L average, reduce the DTI and waive this exception: 1) Revised XXXXXX income worksheet that matches the rationale document provided. Income worksheet in the file qualified with monthly XX K-1 income of $59,843.75 however, the rationale is based on a monthly income of $144,173.00. 2) Client approved exception with verified compensating factors that addresses the borrower's ability to repay (low LTV, number of years on job, FICO score and number of years in home are not sufficient compensating factors) to allow the income to be averaged over 18 months using only the unaudited XX and XX P&L statements. Buyer Comment (2019-08-19): Please see response under "General Ability to Repay" tab. Reviewer Comment (2019-08-19): Another review of the borrower's income has been completed. K-1 and P&L income has been averaged over 2 years and verified income is $59,843.75. Asset depletion income has been revised based on the post-closing CD provided which verifies lower funds required for closing; asset depletion income is now $5,016.40. This results in a DTI of 72.31%. Borrower was qualified with a total rental income of $259.92. File contains a lease agreement for the property at XXXXX however, the total rental income also includes a net rental loss of -$1998.22 for the property at XXXXX. This property was not reported on Schedule E and the lease agreement for this property was not provided. Upon receipt of acceptable rental income verification for the property at XXXXXX, the income and DTI will be reviewed once again. Buyer Comment (2019-08-19): Please see response under "General Ability to Repay" Reviewer Comment (2019-08-19): Received duplicate XX 1065 business return and XX K-1. Re-calculated DTI is 162.80% due to lender qualified with XX K-1 income of $59,843.75 which is not supported by the XX K-1 ordinary income of $366,473.00 less $46,920.00 for unallowed meals = $319,553.00  / 12 months = $26,629.42. Lender income worksheet also reflects $5,833.33 in asset depletion income however, the net amount allowed for depletion is $247,687.28 which is a monthly amount of $2,064.06 calculated as follows: total assets of $1,969,883.52 (includes retirement accounts at 60% usability per Full Doc asset depletion guidelines) less funds for closing of $1,371,637.60 and less required reserves $350,558.64 (includes 12 months for the subject property with a loan amount above $1.5 million and 2 financed rental properties). Per XXXXXX Underwriting Guidelines, the use of the most recent year P&L for qualifying may be considered when the tax returns have not been filed, if there is strong rationale for the utilization of the income and it is well-documented. File is missing the well-documented lender rationale to use the most recent P&L statement for qualifying income. Buyer Comment (2019-08-19): XXXXXXtaxes.  see k1s for income used Reviewer Comment (2019-08-19): The only K-1 in file (XX) supports monthly income of $26,744.54.  Unable to determine source of lender's income calculation. Reviewer Comment (2019-08-19): Updated commentary:  Lender used K-1 income of $59,843.75.  Unable to determine source.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Mortgage history 0 x 30, 95 months on credit report. $18,700 residual income.

Originator Originator

Reviewer Comment (2019-08-19): Rec'd exception for loan amount > $3 million. Buyer Comment (2019-08-19): exception form

05/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Disclosure not evidenced in loan file.

Reviewer Comment (2019-08-19): Attestation approved by AMC in file.

01/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

ATR Risk due to excessive DTI.

Reviewer Comment (2019-08-19): Finally received the lender approved exception to allow the borrower to be qualified with the P&L statement averages only. Lender also finally provided the documented rationale on the XXXXXX letterhead for using the P&L statements for the self-employed borrower's income and matching income worksheet. Reviewer Comment (2019-08-19): See comment under DTI and general ability to repay exceptions. Buyer Comment (2019-08-19): Please see response under "General Ability to Repay" tab. Reviewer Comment (2019-08-19): See additional comments under the DTI exception. Buyer Comment (2019-08-19): Please see response under "General Ability to Repay" Reviewer Comment (2019-08-19): Received duplicate XX 1065 business return and XX K-1. Re-calculated DTI is 162.80% due to lender qualified with XX K-1 income of $59,843.75 which is not supported by the XX K-1 ordinary income of $366,473.00 less $46,920.00 for unallowed meals = $319,553.00  / 12 months = $26,629.42. Lender income worksheet also reflects $5,833.33 in asset depletion income however, the net amount allowed for depletion is $247,687.28 which is a monthly amount of $2,064.06 calculated as follows: total assets of $1,969,883.52 (includes retirement accounts at 60% usability per Full Doc asset depletion guidelines) less funds for closing of $XXXXXXX and less required reserves $350,558.64 (includes 12 months for the subject property with a loan amount above $1.5 million and 2 financed rental properties). Per XXXXXX Underwriting Guidelines, the use of the most recent year P&L for qualifying may be considered when the tax returns have not been filed, if there is strong rationale for the utilization of the income and it is well-documented. File is missing the well-documented lender rationale to use the most recent P&L statement for qualifying income. Buyer Comment (2019-08-19): please see upload Reviewer Comment (2019-08-19): The only K-1 in file (XX) supports monthly income of $26,744.54.  Unable to determine source of lender's income calculation. Reviewer Comment (2019-08-19): Unable to waive. Reviewer Comment (2019-08-19): Ok to waive per client.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

ATR Risk due to excessive DTI.

Reviewer Comment (2019-08-19): Finally received the lender approved exception to allow the borrower to be qualified with the P&L statement averages only. Lender also finally provided the documented rationale on the XXXXXX letterhead for using the P&L statements for the self-employed borrower's income and matching income worksheet. Reviewer Comment (2019-08-19): Received an unsigned and undated rationale paper (that is not on company letterhead) to explain the income calculations. However, in order to provide the investor with acceptable documentation should the borrower's ability to repay ever be questioned, the following is required to revise the income to an 18-month P&L average, reduce the DTI and waive this exception: 1) Revised XXXXXX income worksheet that matches the rationale document provided. Income worksheet in the file qualified with monthly XX K-1 income of $59,843.75 however, the rationale is based on a monthly income of $144,173.00. 2) Client approved exception with verified compensating factors that addresses the borrower's ability to repay (low LTV, number of years on job, FICO score and number of years in home are not sufficient compensating factors) to allow the income to be averaged over 18 months using only the unaudited XX and XX P&L statements. Buyer Comment (2019-08-19): Please refer to XXXXXX comments regarding use of 18 months average P&L net income.     Calculation should be as follows: $144,173 Income $34,514.22 Subject (20 year amortization at 6.33%) $14,854.22 (Second home on XXXXX $12,653.22 + liabilities $2201.00) $49,369.14 Total Ratios 23.94/34.24% Reviewer Comment (2019-08-19): See additional comments under the DTI exception. Reviewer Comment (2019-08-19): Received duplicate XX 1065 business return and XX K-1. Re-calculated DTI is 162.80% due to lender qualified with XX K-1 income of $59,843.75 which is not supported by the XX K-1 ordinary income of $366,473.00 less $46,920.00 for unallowed meals = $319,553.00  / 12 months = $26,629.42. Lender income worksheet also reflects $5,833.33 in asset depletion income however, the net amount allowed for depletion is $247,687.28 which is a monthly amount of $2,064.06 calculated as follows: total assets of $1,969,883.52 (includes retirement accounts at 60% usability per Full Doc asset depletion guidelines) less funds for closing of $XXXXXXX and less required reserves $350,558.64 (includes 12 months for the subject property with a loan amount above $1.5 million and 2 financed rental properties). Per XXXXXX Underwriting Guidelines, the use of the most recent year P&L for qualifying may be considered when the tax returns have not been filed, if there is strong rationale for the utilization of the income and it is well-documented. File is missing the well-documented lender rationale to use the most recent P&L statement for qualifying income. Buyer Comment (2019-08-19): please see upload

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX. (XXXXXX)

Missing XX business and personal tax returns.

Reviewer Comment (2019-08-19): Waive per client.

01/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

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

Final CD reflects closing date of XXXX18.  Loan was consummated on XXXX18.

Reviewer Comment (2019-08-19): Waive per client.

01/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of $74,850.00 on Final Closing Disclosure provided on XXXXXX not accurate. (Final/XXXXXX)

Final CD reflects estimated property costs over year 1 of $74,850.  Calculated amount is $76,539.24 (6,378.XXmo).

Reviewer Comment (2019-08-19): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-08-19): please see attached Reviewer Comment (2019-08-19): AMC did not received documentation related to the exception. The calculated total is $76539.24. HOI $5289.20+Taxes $63750+HOA $7500=$76539.24. Please provide corrected CD and LOE to cure.

07/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Final CD does not reflect a dollar amount by which total closing costs exceeded the legal limit.  Should reflect $100.

Reviewer Comment (2019-08-19): Waive per client.

01/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/XXXXXX)

Disclosure not evidenced in loan file.

Reviewer Comment (2019-08-19): Waive per client.

01/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,250.00 exceeds tolerance of $1,200.00.  Insufficient or no cure was provided to the borrower. (7506)

LE reflects appraisal fee of $1,200.  Final CD reflects appraisal fee of $1,250.  Change of circumstance provided does not provide valid reason for increase.  No cure provided to borrower.

Reviewer Comment (2019-08-19): AMC received XX28 COC. Exception Cleared. Buyer Comment (2019-08-19): This is due to the RUSH fee being $50 more than what's customary and the other $50 in the 2nd appraisal is for the GLA being $50 more than customary for the additional 500 sq ft over the 3k Reviewer Comment (2019-08-19): AMC received Changed Circumstance that indicated fee increased due to complexity of assignment.  Additional information on what the complexity was and why it wasn't known at the time of the initial quote is required.

05/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $1,250.00 exceeds tolerance of $1,200.00.  Insufficient or no cure was provided to the borrower. (7507)

LE reflects second appraisal fee of $1,200.  Final CD reflects second appraisal fee of $1,250.  Change of circumstance provided does not provide valid reason for increase.  No cure provided to borrower.

Reviewer Comment (2019-08-19): AMC received required documents, exception is cleared. Buyer Comment (2019-08-19): Please clear the exception it was cleared on 5/24

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207764044

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX

Reviewer Comment (2019-08-19): XX taxes not used to qualify.  Extension in file.

05/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Reviewer Comment (2019-08-19): Borrower has sufficient reserves.

05/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207764044

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing documentation of new financing for XXXXXX . Received copy of approval for $xxxx. Provide copy Note with P&I payment to be used in final DTI calculation.

Reviewer Comment (2019-08-19): Mortgage statement and cancelled checks / bank printout provided.

05/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207787055

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Note includes assumption verbiage which allows assumptions.  Final Closing Disclosures indicates loan is not assumable.

Reviewer Comment (2019-08-22): Waive per client request.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207787067

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrower was qualified with a P&I payment of $XXXX for the subject 10-year interest only ARM and a DTI of 47.78%. XXXXXX Guidelines and ATR Rules require the loan to be qualified at the fully amortized payment at the greater of the fully indexed or the note rate, to repay the loan over the remaining term after the I/O period. Qualifying P&I payment is $XXXX resulting in a DTI of 52.37%, which exceeds XXXXXX Guideline maximum of 50%.

Borrower has employment stability for 25 years PITIA reserves above minimum by 6 months or greater. Number of PITIA Reserves: 18.64 13.70% LTV < 85 guideline max

Originator Originator Originator

Reviewer Comment (2019-07-31): Waived with comp factors noted

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207787067

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.36998% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower was qualified with a P&I payment of $XXXX for the subject 10-year interest only ARM and a DTI of 47.78%. XXXXXX Guidelines and ATR Rules require the loan to be qualified at the fully amortized payment at the greater of the fully indexed or the note rate, to repay the loan over the remaining term after the I/O period. Qualifying P&I payment is $XXXX resulting in a DTI of 52.37%, which exceeds XXXXXX Guideline maximum of 50%.

Borrower has employment stability for 25 years PITIA reserves above minimum by 6 months or greater. Number of PITIA Reserves: 18.64 13.70% LTV < 85 guideline max

Originator Originator Originator

Reviewer Comment (2019-07-31): Waived with comp factors noted Buyer Comment (2019-07-24): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207787067

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to a DTI of 52.37%, the subject loan is at ATR Risk.

Reviewer Comment (2019-07-31): Cleared as a result of DTI waiver Buyer Comment (2019-07-24): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207787067

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 52.37%, the subject loan is at ATR Risk.

Reviewer Comment (2019-07-31): Cleared as a result of DTI waiver Buyer Comment (2019-07-24): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207787067

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final Closing Disclosure disclosed a Closing Date of XXXXXX. Deed of Trust was notarized on XXXXXX.

Buyer Comment (2019-07-08): please waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207787067

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Right to Cancel was executed by the borrower on XXXXXX. The document date was changed to XXXXXX and the rescission period expiration was changed to XXXXXX with the changes initialed by the borrower. However, the Final Closing Disclosure disclosed a disbursement date of XXXXXX, only providing the borrower with a 2 day rescission period.

Reviewer Comment (2019-08-16): Received certified final settlement statement to verify the subject loan final disbursement date of XXXXXX. Buyer Comment (2019-08-09): disbursed xxx. please see attached final settlement statement Reviewer Comment (2019-07-31): This exception has been reviewed by our compliance department with this response: "The final ALTA settlement statement or wire/funding worksheet prepared by settlement agent is required to evidence the actual disbursement date." The settlement statement provided reflects only the Closing Date. The final settlement statement with the actual disbursement date is required to clear this exception. Buyer Comment (2019-07-24): final settlement statement shows 5/29 disbursement

08/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207787674

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $196.00 exceeds tolerance of $98.00 plus 10% or $107.80.  Sufficient or excess cure was provided to the borrower at Closing.

The Recording fees were disclosed on initial Loan Estimate at $98, but increased to $196 on the final Closing Disclosure.  However, sufficient cure was disclosed.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

207901869

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Note contains assumable language.

Reviewer Comment (2019-08-30): Waive per client request.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901869

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 34,812.12 on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Estimated Property Costs over Year 1 of $34,812.12. Estimated Property Costs are $2,490.59 per month, which equates to calculated Escrowed Property Costs over Year 1 of $29,887.08.

Reviewer Comment (2019-09-04): AMC received tax calculation used. Exception Cleared. Buyer Comment (2019-09-03): property tax used for reassessment of taxes on purXXXXXX.  used higher amount to avoid underdisclosure to borrower.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901869

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Divorce Decree / Child Support not provided

Final 1003 disclosed $3,000.00 monthly child support which was included in the borrower's debts however, file is missing a copy of the divorce decree and/or child support order to verify this amount. Upon receipt of the missing divorce decree and/or child support order, additional conditions may apply.

Reviewer Comment (2019-09-04): Received divorce decree and child support order that verifies $1,500.00 a month in alimony and $1,500.00 a month in  child support for greater than 3 years. Buyer Comment (2019-09-03): divorce decree

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901871

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-08-23): Waive per client request.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901873

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

3 day appraisal waiver provided however proof that appraisal was delivered to borrower by closing date was not provided.

Reviewer Comment (2019-08-26): Waive per client request.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207901873

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

CD reflects loan is not assumable however loan is a ARM and non-assumability rider was not provided.

Reviewer Comment (2019-08-26): Waive per client request.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901876

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD reflects loan is not assumable however non-assumability rider was not provided.

Reviewer Comment (2019-08-30): Waive per client request.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901876

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/XXXX 12:00:00 AM was received.

Reviewer Comment (2019-08-30): Waive per client request.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207901876

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

CD closing date XXXX19, borrower's signature date XXXX19

Reviewer Comment (2019-08-30): Waive per client request.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901878

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Non-Assumability Rider to the Note was not provided at the time of audit review.

Reviewer Comment (2019-09-04): EV2, waived at client request

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901878

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Consumer(s) Final CD disclosed Closing Date XXXXXX, however consummation took place on XXXXXX as indicated by wet signature(s).

Reviewer Comment (2019-09-04): EV2, waived at client request

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901878

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees seller paid fees do not match Consumer's Final CD

TILA-RESPA Integrated Disclosure: the Seller's final CD total seller paid fee amounts do not match the values used for compliance testing.

Additional Seller paid fee was not disclosed on Consumer(s) Final CD and there were discrepancies in fees between the two disclosures at the time of consummation.

Reviewer Comment (2019-09-04): EV2, waived at client request

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901888

XXXXXX

XXXXXX

Credit

Property - Appraisal

General Appraisal Requirements

Subject is a refinance and property is listed for sale.

-

Per the appraisal, the subject property has been listed on the market for 107 days (XXXXXX) however, file is missing verification the subject property is off the market before receiving cash-out on the subject cash out refinance, or a lender approved exception with strong compensating factors to allow cash-out on a listed property as required by XXXXXX Underwriting guidelines.

Reviewer Comment (2019-09-04): Received redfin.com listing history which verifies the subject property was delisted (cancelled) on XXXXXX, prior to the subject loan closing on XXXXXX.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901888

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Non-Assumability Rider to the Note was not provided at the time of audit review.

Reviewer Comment (2019-08-26): Waive per client request.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207901892

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

File contains a lender exception to allow a desk review in lieu of the required 2nd appraisal for the subject loan amount of $xxxx however, file is missing the desk review.

Reviewer Comment (2019-07-10): Received Buyer Comment (2019-07-05): appraisal review

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207901892

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Missing Data) Last Rate Set Date

Last Date Rate Set and Initial Rate Lock Date not provided.  Worst Case Scenario between Creditor Application Date and Transaction Date used to determine rate used for testing.

File is missing the Rate Lock confirmation.

Buyer Comment (2019-07-05): please waive

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207901892

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final Closing Disclosure disclosed a Closing Date of XXXXXX. Deed of Trust was notarized on XXXXXX.

Buyer Comment (2019-07-05): please waive

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207901892

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Hazard Insurance Policy reflects an effective date of XXXXXX which is after the closing date of XXXXXX and the subject loan disbursement date of XXXXXX.

Reviewer Comment (2019-07-08): Cleared Buyer Comment (2019-07-05): final settlement statement shows closed 5/31, after insrance effective date

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207901892

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The loan file did not contain a non assumable rider - Note confirmed assumable - CD disclosed not assumable

Reviewer Comment (2019-07-03): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207901892

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower was qualified with $12,000.00 in monthly income from a new consulting contract with the consulting income paid to the borrower's company XXXXXX  with an effective date of XXXXXX. Documentation was not provided to verify that XXXXXX  has been in existence for 2 years and the file is missing business tax returns, K-1's and a YTD P&L statement covering the period since the last tax return was filed as required by XXXXXX Full Doc guidelines. Without this income, the DTI increased to 63.62% which exceeds the guideline maximum of 50%.

Borrower has residual income of $8,167.03 (excluding the $12,000.00 monthly income from a new consultant contract that will be paid to a new business the borrower just created and lack of income documentation was waived by XXXXXX) Housing payment history clean for 29 months 31.57 months reserves > 12 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-08-31): Finally received a 3rd party verification of the borrower's newly formed business, XXXXXX In addition, client approved an exception to allow the borrower to be qualified with 100% of the monthly income of $12,000.00 from a consulting contract dated XXXXXX with the income being paid solely to XXXXXX DTI is now 42.44%. Buyer Comment (2019-08-12): please see lender response regarding XXXXXX Reviewer Comment (2019-08-12): Received lender exception to allow the borrower to be qualified with a new consulting contract with income payable to a company and not the borrower personally. On XXXXXX a XXXXXX corporation filing for XXXXXX was uploaded. As of XXXXXX, still have not received a CPA letter or 3rd party verification for XXXXXX to verify the borrower is 100% owner of this company that is being paid as the contractor for XXXXXX. Exception remains. Reviewer Comment (2019-07-31): Revised comment. The new consulting contract dated XXXXXX is between XXXXXX(the "Company") and XXXXXX(the "Consultant"). No documentation was provided in the file to verify the borrower owns XXXXXX. In addition, if the consulting income is paid to a business the borrower owns, then that is self-employed income. Per XXXXXX self-employed income guidelines, the business must be in existence for 2 years and the self-employed income must be verified with the most recent business tax returns, K-1's and a YTD P&L statement covering the period since the last tax return was filed. Without this income, the DTI is 63.62%, which exceeds the guideline maximum of 50%. Buyer Comment (2019-07-24): XXXXXX is the "Company" that is hiring the borrower as a consultant.

08/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207901892

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 63.62432% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Borrower was qualified with $12,000.00 in monthly income from a new consulting contract with the consulting income paid to the borrower's company XXXXXX with an effective date of XXXXXX. Documentation was not provided to verify that XXXXXX  has been in existence for 2 years and the file is missing business tax returns, K-1's and a YTD P&L statement covering the period since the last tax return was filed as required by XXXXXX Full Doc guidelines. Without this income, the DTI increased to 63.62% which exceeds the guideline maximum of 50%.

Reviewer Comment (2019-08-31): Finally received a 3rd party verification of the borrower's newly formed business, XXXXXX. In addition, client approved an exception to allow the borrower to be qualified with 100% of the monthly income of $12,000.00 from a consulting contract dated XXXXXX with the income being paid solely to XXXXXX DTI is now 42.44%. Buyer Comment (2019-08-12): see upload Reviewer Comment (2019-08-12): Received lender exception to allow the borrower to be qualified with a new consulting contract with income payable to a company and not the borrower personally. On XXXXXX a XXXXXX corporation filing for XXXXXX was uploaded. As of XXXXXX, still have not received a CPA letter or 3rd party verification for XXXXXX to verify the borrower is 100% owner of this company that is being paid as the contractor for XXXXXX Exception remains. Buyer Comment (2019-08-02): Please see response provided under "Investor qualifying total debt ratio discrepancy" tab. Reviewer Comment (2019-07-31): Revised comment. The new consulting contract dated XXXXXX is between XXXXXX (the "Company") and XXXXXX(the "Consultant"). No documentation was provided in the file to verify the borrower owns XXXXXX. In addition, if the consulting income is paid to a business the borrower owns, then that is self-employed income. Per XXXXXX self-employed income guidelines, the business must be in existence for 2 years and the self-employed income must be verified with the most recent business tax returns, K-1's and a YTD P&L statement covering the period since the last tax return was filed. Without this income, the DTI is 63.62%, which exceeds the guideline maximum of 50%. Buyer Comment (2019-07-24): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

08/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207901892

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to unverified self-employed income and a DTI of 63.62%, the subject loan is at ATR Risk.

Reviewer Comment (2019-08-31): Finally received a 3rd party verification of the borrower's newly formed business, XXXXXX. In addition, client approved an exception to allow the borrower to be qualified with 100% of the monthly income of $12,000.00 from a consulting contract dated XXXXXX with the income being paid solely to XXXXXX DTI is now 42.44%. Buyer Comment (2019-08-12): see upload Reviewer Comment (2019-08-12): See comment under DTI exception. Buyer Comment (2019-08-02): Please see response provided under "Investor qualifying total debt ratio discrepancy" tab. Reviewer Comment (2019-07-31): See comment under DTI exceptions. Buyer Comment (2019-07-24): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

08/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207901892

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to unverified self-employed income and a DTI of 63.62%, the subject loan is at ATR Risk.

Reviewer Comment (2019-08-31): Finally received a 3rd party verification of the borrower's newly formed business, XXXXXX In addition, client approved an exception to allow the borrower to be qualified with 100% of the monthly income of $12,000.00 from a consulting contract dated XXXXXX with the income being paid solely to XXXXXX. DTI is now 42.44%. Buyer Comment (2019-08-12): see upload Reviewer Comment (2019-08-12): See comment under DTI exception. Buyer Comment (2019-08-02): Please see response provided under "Investor qualifying total debt ratio discrepancy" tab. Reviewer Comment (2019-07-31): See comment under DTI exceptions. Buyer Comment (2019-07-24): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

08/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207901892

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Most recent personal tax returns are dated XXXXXX.

Buyer Comment (2019-07-08): please waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207901892

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Most recent personal tax returns are dated XXXXXX.

Buyer Comment (2019-07-05): please waive

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207901893

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

File is missing the secondary valuation required for securitization.

Reviewer Comment (2019-08-01): Cleared, 2nd appraisal provided. Buyer Comment (2019-07-22): appraisal 1 and 2

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

B

B

C

A

Non QM

Non QM

No

207901893

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note reflects Assumption verbiage in section 11B.  A Non Assumability Addendum was not provided and the Borrower's Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-07-03): Waiver per client request.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

B

B

C

A

Non QM

Non QM

Yes

207901956

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXX exceeds tolerance of $525.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901956

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Closing Costs Exceeds Limits Amount

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed a tolerance cure amount that does not match the amount disclosed in the Other Costs table.

Page 3 of final CD is missing cure amount of $52.50 on the Calculating Cash to Close section "Exceeds legal limit by"

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901956

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Page 3 of final CD is missing cure amount of $52.50 on the Calculating Cash to Close section "Exceeds legal limit by"

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901957

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-03): XXXXXX has elected to waive this exception.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Reviewer Comment (2019-07-03): Appraisal provided

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Appraisal is missing from file, unable to determine date inspected

Reviewer Comment (2019-07-03): Appraisal provided. Buyer Comment (2019-07-03): Please see uploaded appraisal

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Reviewer Comment (2019-07-23): AMC received the HOI policy with mortgagee clause containing the ISAOA.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2019-07-03): Appraisal provided.

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-03): Appraisal provided.

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.72470% or Final Disclosure APR of 8.77600% is in excess of allowable threshold of APOR 4.58% + 1.5%, or 6.08000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-03): Appraisal provided.

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

Unable to determine if Safe Harbor requirements are met due to missing information.

Reviewer Comment (2019-07-03): Appraisal provided. Buyer Comment (2019-07-03): Please see uploaded appraisal

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Reviewer Comment (2019-07-03): Appraisal provided. Buyer Comment (2019-07-03): Please see uploaded appraisal

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2019-07-03): Appraisal provided. Buyer Comment (2019-07-03): Please see uploaded appraisal

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Appraisal Flipped Property Missing Information

Last Sales Price or Last Sales Date from the Primary Valuation or Contract Sales Price or Contract Sales Date are missing. Unable to determine compliance with TIL HPML Flipped Property Requirements.

Reviewer Comment (2019-07-03): Appraisal provided. Buyer Comment (2019-07-03): Please see uploaded appraisal

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Counseling Disclosure issued XXXX19 but not signed by Borrower until XXXX19

Buyer Comment (2019-07-18): XXXXXX has elected to waive

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 8.72470% is in excess of allowable threshold of Prime Mortgage Market Rate 3.66000% + 1.75%, or 5.41000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-18): XXXXXX has elected to waive

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901958

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Reviewer Comment (2019-07-03): Effective date was XXXXXX

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207901959

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation disclosure not in file. Unable to determine if compensation was based on a term of the transaction

Buyer Comment (2019-07-02): XXXXXX has elected to waive this exception.

07/02/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901959

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Final Closing Disclosure Finance Charge is under disclosed by $200.  Itemization of amount financed not in file to confirm please provide compliance report as required per guides.

Reviewer Comment (2019-07-11): AMC received PCCD, LOE, refund check, and proof of delivery. Exception Cured. Buyer Comment (2019-07-10): Please see PCCD, LOX, CHECK LABEL Reviewer Comment (2019-07-09): AMC received LE. The exception is regarding the discrepancy of the finance charge amount. As it appears the HOA/Condo Questionnaire was required by lender as it was disclosed in section B on the LE thus included in APR. Please provide corrected CD, LOE, refund check, and proof of delivery to cure. Buyer Comment (2019-07-08): Please see INITIAL LE reflecting the $250 condo fee was disclosed in section B Reviewer Comment (2019-07-03): AMC received Mavent Compliance Report, it appears the HOA/Condo Questionaire fee of $250 was not included in the APR calculation.  As it was disclosed in Section C as a required fee by title, it is an APR fee.  If it is not a fee required by the lender or the title company, then it should be disclosed in Section H to be omitted from the APR calculation. Buyer Comment (2019-07-03): Please see Compliance Report

07/11/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901960

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-02): XXXXXX has elected to waive this exception.

07/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901960

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $774.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing.

06/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207901960

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Co-borrower was self-employed as majority Owner of XXXXXX and has entered into an asset purchase agreement with XXXXXX . Borrower has been retained as XXXXXX  since XXXX19 and received a salary. Allow income verified with employment contract, recent paystubs and previous 2 years tax returns verifying self employment income vs program requirement of verifying income with 1 months paystubs and W2 for the previous calendar year. Lender acknowledged. Per income documentation from XX taxes income is not supported at current amount XX Schedule C reflects $XXXXX loss + $XXXX depreciation - meal and expenses $XXX. monthly income$2,760.17.

38.57467% DTI < 50% guideline max - 11.42533 % below program guideline maximum 85.36 months reserves > 6 months guideline minimum by 79.36 months. Credit score is 761, 81 points > program requirement of 680.  Prefect mortgage history paid as agreed since earliest inception 2/2008.  All tradelines paid as agreed since earliest account inception in 2005 and no public records.

Originator Originator Originator

Reviewer Comment (2019-07-15): Per FNMA, borrower started new employment which requires employment contract and recent paystub. Reviewer Comment (2019-07-11): Unable to tell which borrower contributes to the majority of the income reflected for Schd C. Co-borrower's business structure for XX was S-Corp and XX reflects only Schd C income. Buyer Comment (2019-07-11): Please see page #563 of the original uploaded docs for the XX Transcripts. Reviewer Comment (2019-07-10): Per lender exception approval to use recent paystub and 2 years tax returns in lieu of paystubs and W-2's from previous years. Provide XX tax returns, which are missing from file, to justify using current income. Buyer Comment (2019-07-09): Uploaded For Review-Employment Contract. K-1 and W2's not requested due to exception allowing income based solely on earnings from employment contract. Reviewer Comment (2019-07-09): To escalate, please provide pages 1 - 5 of employment contract not found in file. Also need XX K-1 and if applicable W-2's for XX and XX. Buyer Comment (2019-07-08): Please escalate- Exception approval is to allow income reflected on co-borrower's employment contract w/ XXXX, in the amount of $100,000 yearly, $8,333 monthly to be considered as qualifying earnings.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901961

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow self-employment of 11 months with 10 month business bank statements averaged over 12 months vs. program requirement of 24 months self-employment with 12 months business bank statement (Side Note: no income first month, 10 months bank statements averaged over 12 months)

Perfect credit with all accounts paid as agreed and no public records Borrower was previously a XXXXXX for 14 years prior to becoming self-employed for the past 11 months in the same profession (XXXXXX) and has worked on XXXXXX Credit score is 793, 113 points > program requirement of 680

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-02): Client has elected to waive this exception based on compensating factors.

07/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901961

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Closing Costs Exceeds Limits Amount

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed a tolerance cure amount that does not match the amount disclosed in the Other Costs table.

Tolerance cure in section J on page 2 of Final CD is $19.00. Tolerance cure on page 3 calculating cash to close is blank.

Reviewer Comment (2019-07-08): Letter of Explanation & Corrected Closing Disclosure provided. Buyer Comment (2019-07-05): Uploaded For Review-PCCD Docs

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901961

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD disclosed a tolerance cure of $19.00; calculated cure is $199.10.

Reviewer Comment (2019-07-08): Letter of Explanation & Corrected Closing Disclosure provided. Buyer Comment (2019-07-05): Uploaded For Review-PCCD Docs

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901961

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,775.00 exceeds tolerance of $2,359.00 plus 10% or $2,594.90.  Insufficient or no cure was provided to the borrower.

The CD issued on XXXX19 increased the Title Fees paid to vendor on provider list without a valid change of circumstance.

Reviewer Comment (2019-07-08): See new added exception. Buyer Comment (2019-07-05): Uploaded For Review-PCCD Docs

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901961

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $519.00 exceeds tolerance of $500.00.  Insufficient or no cure was provided to the borrower.

The CD issued on XXXX19 increased the Appraisal Fee without a valid change of circumstance.

Reviewer Comment (2019-07-08): See new added exception. Buyer Comment (2019-07-05): Uploaded For Review-PCCD Docs

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901961

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD.

The Borrower's CD disclosed seller paid fees of $26,471.26; the Seller's CD disclosed $28,691.26.  The Borrower's CD did not disclose the Pest Inspection Fee of $1875.00, Title - Inspection Fee of $95.00, Title - Messenger Fee of $100.00, Title - Processing Demands fee of $100.00 and Recording Fees of $50.00 that were disclosed on the Seller's CD.

Reviewer Comment (2019-07-08): Revised Seller's CD provided.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901961

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Do not require funds to be transferred from business account into borrower's personal account for down payment and closing costs vs program requirement that funds to close are transferred to the borrower's personal account. Lender acknowledged.

Perfect credit with all accounts paid as agreed and no public records Borrower was previously a XXXXXX for 14 years prior to becoming self-employed for the past 11 months in the same profession (XXXXXX) and has worked on XXXXXX Credit score is 793, 113 points > program requirement of 680

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-02): Client has elected to waive this exception based on compensating factors.

07/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901961

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,775.00 exceeds tolerance of $2,359.00 plus 10% or $2,594.90.  Sufficient or excess cure was provided to the borrower.

PCCD, LOE, check and POD provided.

Reviewer Comment (2019-07-08): Letter of Explanation, copy of refund check & Corrected Closing Disclosure provided.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901961

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $519.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower.

PCCD, LOE, check and POD provided.

Reviewer Comment (2019-07-08): Letter of Explanation, copy of refund check & Corrected Closing Disclosure provided.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901962

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Approved lender exception doc 5 for DTI of 52.67% vs. program max of 50%.

Perfect credit with all accounts paid as agreed, no public records. Borrower self-employed for past 25 years. 17.67 months reserves vs. program required 3 months. 814 credit score vs. program min 640. 80% LTV vs. program max of 85%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-03): Client has elected to waive this exception based on compensating factors.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901962

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.66284% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

ATR risk due to DTI exceeding program max of 50%, approved lender exception in file.

Perfect credit with all accounts paid as agreed, no public records. Borrower self-employed for past 25 years. 17.67 months reserves vs. program required 3 months. 814 credit score vs. program min 640. 80% LTV vs. program max of 85%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-03): Client has elected to waive this exception based on compensating factors.

07/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901962

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901962

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901962

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller Closing Disclosure not provided

Reviewer Comment (2019-07-09): AMC received required documents, exception is cleared. Buyer Comment (2019-07-08): Seller CD uploaded.

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901962

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Not provided, field not shown on final CD.  No cure provided for transcripts overage.

Buyer Comment (2019-07-09): XXXXXX has elected to waive this exception.

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901962

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Tax Return Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided for overage, tax transcripts fee added without VCC.

Reviewer Comment (2019-07-09): AMC received  Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD. Buyer Comment (2019-07-08): PCCD/LOX/Refund/Label uploaded.

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901962

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Tax Return Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

Cured post closing.

Buyer Comment (2019-07-09): XXXXXX has elected to waive this exception.

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901963

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Buyer Comment (2019-07-05): XXXXXX has elected to waive this exception. Buyer Comment (2019-07-03): Uploaded For Review- Proof of receipt of appraisal w/in 3 days of closing

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901963

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Total Cost Closing exceeded the legal limit and no cure provided.

Reviewer Comment (2019-07-05): AMC received XX17 COC. Exception Cleared.

07/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901963

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing documentation

Buyer Comment (2019-07-01): XXXXXX has elected to waive this exception.

07/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901963

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXXX exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Loan discount points changed to mortgage broker fee on XXXXXX Loan Estimate without proof of valid change

Reviewer Comment (2019-07-05): AMC received XX17 COC. Exception Cleared. Buyer Comment (2019-07-03): Uploaded For Review- COC

07/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901964

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

CDA missing from file.

Reviewer Comment (2019-07-08): CDA provided. Buyer Comment (2019-07-05): Uploaded For Review-CDA

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

C

A

Non QM

Non QM

No

207901964

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Borrowers waived appraisal timing rights, evidence if/when report was provided to borrowers is missing from file.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

C

A

Non QM

Non QM

No

207901964

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.56030% or Final Disclosure APR of 7.57300% is in excess of allowable threshold of APOR 3.86% + 1.5%, or 5.36000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-08): Proof of Receipt of Appraisal provided. Buyer Comment (2019-07-08): Uploaded For Review-appraisal receipt Reviewer Comment (2019-07-08): Exception is based on Proof of Receipt of Appraisal is dated XXXXXX, however the appraisal report date is XXXXXX. Buyer Comment (2019-07-05): XXXXXX Mortgage purXXXXXXs High Priced Mortgage Loans

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

C

A

Non QM

Non QM

No

207901964

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Borrowers waived appraisal timing rights, evidence if/when report was provided to borrowers is missing from file.

Reviewer Comment (2019-07-08): Proof of Receipt of Appraisal provided. Reviewer Comment (2019-07-08): Proof of Receipt of Appraisal is dated XXXXXX, however the appraisal report date is XXXXXX. Buyer Comment (2019-07-05): Uploaded For Review- Proof of Receipt of Appraisal

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

C

A

Non QM

Non QM

No

207901964

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-02): XXXXXX has elected to waive this exception.

07/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

C

A

Non QM

Non QM

No

207901964

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The note does not contain assumption language.  The CD indicates the loan allows for assumption.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

C

A

Non QM

Non QM

Yes

207901965

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Missing evidence XXXXXX transferred the appraisal to XXXXXX

Reviewer Comment (2019-07-08): Agree with lender. Buyer Comment (2019-07-08): XXXXXX is a DBA Reviewer Comment (2019-07-08): Appraisal release reflects XXXXXX, lender should be XXXXXX

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

B

C

B

B

A

Non QM

Non QM

No

207901965

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Missing evidence borrower was provided the E-Sign Consent disclosures.

Reviewer Comment (2019-07-08): E-consent provided.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

B

C

B

B

A

Non QM

Non QM

No

207901965

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $4,035.75 and disclosure timing violations.

Missing the E-Consent form.  May result in fee tolerance violation up to $4,035.75

Reviewer Comment (2019-07-08): E-consent provided.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

B

C

B

B

A

Non QM

Non QM

No

207901965

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charge is under disclosed by $500 for the escrow PAD amount.

Reviewer Comment (2019-07-11): Letter of Explanation, Proof of Delivery and Corrected CD provided.  Confirmed $500 not charged to borrower from Final Settlement Statement. Reviewer Comment (2019-07-10): AMC received PCCD removing PAD fee. Please provide final settlement statement to verify if fee was charged. Buyer Comment (2019-07-09): Charge on Page 2 ins section H of uploaded CD

07/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

B

C

B

B

A

Non QM

Non QM

Yes

207901965

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure PAD Fee

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX disclosed a Pad fee that was not allocated to a specific cost or service performed.

A 'Pad" was disclosed on the final CD in section H that was not allocated to a specific cost or service.

Reviewer Comment (2019-07-11): Letter of Explanation, Proof of Delivery and Corrected CD provided.  Confirmed $500 not charged to borrower from Final Settlement Statement. Reviewer Comment (2019-07-10): AMC received PCCD removing PAD fee. Please provide final settlement statement to verify if fee was charged. Buyer Comment (2019-07-09): Charge on Page 2 ins section H of uploaded CD

07/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Pad Refund Check if applicable, and Corrected CD

C

B

A

B

C

B

B

A

Non QM

Non QM

Yes

207901965

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD is blank in the section by which the Total Closing Costs exceeded the legal limit. Actual cost to cure is $500.00 No evidence in file that cure provided to borrower.

Reviewer Comment (2019-07-11): Letter of Explanation, Proof of Delivery and Corrected CD provided.  Confirmed $500 not charged to borrower from Final Settlement Statement. Reviewer Comment (2019-07-10): AMC reviewed exception. Please provide final settlement statement to verify if fee was charged. Buyer Comment (2019-07-09): Charge on Page 2 ins section H of uploaded CD Reviewer Comment (2019-07-08): AMC received PCCD removing PAD fee. Please provide final settlement statement to verify if fee was charged. Buyer Comment (2019-07-08): Please see uploaded PC CD

07/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

B

C

B

B

A

Non QM

Non QM

Yes

207901965

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for PAD.  Fee Amount of $500.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Zero percent fee tolerance exceeded by $500.00. No evidence cure provided to borrower.

Reviewer Comment (2019-07-11): Letter of Explanation, Proof of Delivery and Corrected CD provided.  Confirmed $500 not charged to borrower from Final Settlement Statement. Reviewer Comment (2019-07-10): AMC reviewed exception. Please provide final settlement statement to verify if fee was charged. Buyer Comment (2019-07-09): Charge in page 2 in section H Reviewer Comment (2019-07-08): AMC received PCCD removing PAD fee. Please provide final settlement statement to verify if fee was charged. Buyer Comment (2019-07-08): Please see uploaded PC CD

07/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

B

C

B

B

A

Non QM

Non QM

Yes

207901965

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Reviewer Comment (2019-07-16): Client elects to waive the exception with verified compensation factors

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

A

B

C

B

B

A

Non QM

Non QM

Yes

207901965

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs don't match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTIs calculated in accordance with the Lenders Guidelines of 51.20464% and based on 1026.43(c)(5) of 50.93% moderately exceed the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Perfect credit history since XXXXXX Reserves are 15.97 months, 7.97 months > program requirement of 8 months 756 representative FICO score > 640 guideline minimum - 116 points above guideline minimum

Originator Originator Originator

Reviewer Comment (2019-07-16): Client elects to waive the exception with verified compensation factors

07/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

B

C

B

B

A

Non QM

Non QM

No

207901965

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

.

Perfect credit history since XXXXXX Reserves are 15.97 months, 7.97 months > program requirement of 8 months 756 representative FICO score > 640 guideline minimum - 116 points above guideline minimum

Originator Originator Originator

Reviewer Comment (2019-07-16): Client elects to waive the exception with verified compensation factors

07/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

B

C

B

B

A

Non QM

Non QM

No

207901968

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901968

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD provided a tolerance cure of $386.05; calculated cure is $881.05.

Reviewer Comment (2019-07-10): Letter of Explanation & Corrected Closing Disclosure provided. Buyer Comment (2019-07-10): uploaded pccd/refund

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901968

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $495.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Second Appraisal Fee was added to the LE issued on XXXX19 without a valid change of circumstance.

Reviewer Comment (2019-07-10): Cured

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901968

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $450.05 exceeds tolerance of $64.00.  Insufficient or no cure was provided to the borrower.

The final CD increased the Credit Report Fee without a valid change of circumstance.

Reviewer Comment (2019-07-09): Cured at closing. Buyer Comment (2019-07-08): cure applied on final cd

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901968

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

Subject purchase is a non-arm's length transaction; borrower currently rents the subject property.  Property is professionally managed and the rental history is reporting to credit since XXXX under EDC/PPG Property Management.  Allow the verification of rent reporting on credit in lieu of cancelled rent checks vs program requirement that rental history must be verified with 12 months cancelled checks.

VOR reflects paid as agreed since inception of account XXXXXX.  One closed mortgage reporting paid as agreed. Borrower is XXXXXX in the same line of work for the past 13 years. DTI is 36.888%, 13.112% < program maximum of 50%. Reserves are 16.59 months, 13.59 months > program requirement of 3 months. Credit score is 658, 18 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-05): Client has elected to waive this exception based on compensating factors.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901968

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

This discrepancy is caused by the HOA dues of $62 per month disclosed on the appraisals. The final CD reflects a figure of $62.33 per month. The Desk Review in file does indicate the dues are $187 quarterly which matches the monthly reserve reflected in the final CD. Need documentation to support.

Reviewer Comment (2019-07-10): Letter of Explanation & Corrected Closing Disclosure provided.

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901968

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $495.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

PCCD, LOE, Check and POD received.

Reviewer Comment (2019-07-10): Letter of Explanation, refund check, POD & Corrected Closing Disclosure received.

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901968

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $450.05 exceeds tolerance of $64.00.  Sufficient or excess cure was provided to the borrower.

Cured at closing

Reviewer Comment (2019-07-10): Cured at closing

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901969

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow borrower to be treated as Type 1 borrower even though he purchases materials vs. purchases of materials disqualify for Type 1.

Perfect credit history since earliest account inception 9/2016. No public records. Reserves are 13 months, 10 months > program requirement of 3 months ($5,337.30) Credit score is 724, 44 points > program requirement of 680 Borrower's tax preparer providing a P&L statement and signing a notarized declaration that the P&L is correct. Borrower does light construction with some expenses for materials but no employees, limited expenses. Bank statements reasonably support the P&L statement. Borrower has been XXXXXX as owner of XXXXXX for the past 6 years.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-01): Client has elected to waive this exception based on compensating factors.

07/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901969

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-07-03): Borrower Ability to Repay Attestation provided Buyer Comment (2019-07-02): Borrower ATR for review

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901969

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: Closing Disclosure is incomplete

Seller's final CD is missing page1

Reviewer Comment (2019-07-03): Complete Seller CD provided. Buyer Comment (2019-07-02): Seller CD for review

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901969

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-01): XXXXXX has elected to waive this exception.

07/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901969

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $505.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing.

06/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207901970

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided the LO Compensation Disclosure at time of application.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207901970

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final CD reflects closing date as XXXX19 yet date of consummation is XXXX19.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207901972

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing all pages of fully executed  Divorce Decree to support any possible undisclosed debt (where applicable).

Reviewer Comment (2019-06-18): AMC received the Divorce Decree of a total of 1 page and LOE from Borrower that it was non-contested and contained only 1 page dated 5/XX19. Buyer Comment (2019-06-17): Divorce Decree consist of one page - see DD and LOX

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901972

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-08-06): Borrower Ability to Repay Attestation provided Buyer Comment (2019-08-05): Attestation provided

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901972

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Borrower does not have the minimum active tradelines per guidelines.

Borrower has only 2 active tradelines with only 2 monthly reviews,vs guideline requirement of two trade lines that have (i) been active within the twelve months prior to the date of the Borrower's consumer credit report, and (ii) have been established for twelve months or longer.

No public records Borrower is self-employed for 8 years - XXXXXX, same line of work 35 years. 30.56455% DTI on this Alt documentation loan < 50% guideline max - 19.43545% below program guideline maximum. FICO Score of 668, 28 points > Program Requirement of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-25): Borrower has 1 active tradeline for over 4 years (VOR) and 2 opened for 4 months (2/XX) plus several closed vs program requirement of 3 tradelines of which 2 must be active within the past 12 months. Buyer Comment (2019-06-24): Re-uploaded approved revised credit exception Reviewer Comment (2019-06-24): No Credit Exception uploaded to file in trailing docs. Buyer Comment (2019-06-24): See approved XXXXXX Credit Exception uploaded

06/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901972

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

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

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

Buyer Comment (2019-06-27): XXXXXX has elected to waive this exception.

06/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901972

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX HPML Threshold Test Non-Compliant

XXXXXX Higher-Priced Mortgage Loan: APR on subject loan of 8.26000% or Final Disclosure APR of 8.34100% is in excess of allowable threshold of APOR 4.03% + 1.5%, or 5.53000%.  Non-Compliant Higher Priced Loan.

Buyer Comment (2019-06-27): XXXXXX has elected to waive this exception.

06/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901972

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee. Fee Amount of $150.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing

06/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207901972

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow the use of business funds without a CPA letter (borrower does not utilize a CPA) vs program requirement to obtain a statement from a Certified Public Accountant or Professional tax preparer stating that the withdrawal of funds will not have a negative impact on the business. Lender exception

No public records Borrower is self-employed for 8 years - XXXXXX, same line of work 35 years. 30.56455% DTI on this Alt documentation loan < 50% guideline max - 19.43545% below program guideline maximum. FICO Score of 668, 28 points > Program Requirement of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-14): Client has elected to waive this exception based on compensating factors.

06/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901973

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

2.63 months of reserves insufficient to cover 3 months required per guidelines.

Borrower has been self employed for 5 years and  in the profession for 7 years. FICO is 665, 25 points > program requirement of 640 LTV is 80%, 5% < maximum program 85%

Originator Originator Originator

Reviewer Comment (2019-07-10): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-10): Approved XXXXXX Credit Exception uploaded Reviewer Comment (2019-07-08): Available funds for closing are $150,665.07 - $132,477.79 (funds to close) = $18,187.28. PITI of $6088.69 x 3 = $18266.07. Short reserves of $78.79. Buyer Comment (2019-07-05): Please see Final CD - total cash to close minus available assets = sufficient reserves to meet guideline requirement.

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901973

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.72600% or Final Disclosure APR of 7.84900% is in excess of allowable threshold of Prime Mortgage Market Rate 4.07000 + 1.75%, or 5.82000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-05): XXXXXX has elected to waive this exception.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901973

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Counseling Disclosure for XXXXXX Subprime was not issued within three days of application.

Buyer Comment (2019-07-05): XXXXXX has elected to waive this exception.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901973

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit Disclosure is not located in file.

Buyer Comment (2019-07-05): XXXXXX has elected to waive this exception.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901974

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Missing subject Note.

Reviewer Comment (2019-07-23): AMC received the signed and date Note. Buyer Comment (2019-07-23): Note uploaded for review.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

A

C

A

D

A

A

A

Non QM

Non QM

No

207901974

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Qualifying interest rate discrepancy.

Qualifying interest rate of ___ does not match Guideline qualifying interest rate of ___.

Lender qualified the borrower at the Note rate vs. the greater of the fully indexed rate or the note rate as required per guidelines.

Reviewer Comment (2019-07-24): Lender approval dated XXXXXX shows qualifying rate of 5.960% which is the note rate. A revised Approval and 1008 shows a qualifying rate of 6.369%. DTI on 1008 is 34.504%. Calculated final DTI is 34.79906. Guideline maximum is 43%.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

A

C

A

D

A

A

A

Non QM

Non QM

No

207901976

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

The policy effective date is XXXX19; the notary date (consummation ) is XXXX19.

Reviewer Comment (2019-07-10): Policy Effective Date of XXXXXX matches consummation date of XXXX2020.Policy Effective Date of XXXXXX matches disbursement date of XXXX2020. Buyer Comment (2019-07-09): Corrected HOI Reviewer Comment (2019-07-08): Effective date has been corrected however, the expiration date reflects XXXX2010. Correct year to 2020. Buyer Comment (2019-07-04): HOI corrected Loan disbursed 6/21

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901976

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-01): XXXXXX has elected to waive this exception.

07/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901976

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The final CD disclosed a closing date of XXXX19; documents were signed on XXXX19.

Buyer Comment (2019-07-01): XXXXXX has elected to waive this exception.

07/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207901977

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

Missing Document: Flood Insurance Policy not provided

Reviewer Comment (2019-06-27): AMC received the flood policy dated XXXX18-XXXX19. Buyer Comment (2019-06-26): Flood policy provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Missing from file.

Buyer Comment (2019-06-26): XXXXXX has elected to waive this exception.

06/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Missing e-sign consent.

Reviewer Comment (2019-06-27): AMC received E Consent dated XXXXXX. Exception Cleared. Buyer Comment (2019-06-26): Econsent provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Copy Or Fax Fee.  Fee Amount of $13.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided for overage, copies fee added without VCC.

Reviewer Comment (2019-06-27): AMC received SSPL dated XXXXXX. Exception Cleared. Buyer Comment (2019-06-26): See COC provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Services Sales Tax.  Fee Amount of $53.25 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided for overage,sales tax fee added without VCC.

Reviewer Comment (2019-06-27): AMC received SSPL dated XXXXXX. Exception Cleared. Buyer Comment (2019-06-26): See COC provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing from file.

Buyer Comment (2019-06-26): XXXXXX has elected to waive this exception.

06/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Evidence of earlier receipt missing from file, one and only CD received.

Reviewer Comment (2019-06-27): AMC received XX10 CD received the same day. Exception Cleared. Buyer Comment (2019-06-26): Initial CD provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing from file.

Reviewer Comment (2019-06-27): AMC received SSPL dated XXXXXX. Exception Cleared. Buyer Comment (2019-06-26): SSPL provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $19,123.25 and disclosure timing violations.

Missing e-sign consent, all fee baselines are $0.00.

Reviewer Comment (2019-06-27): AMC received E Consent dated XXXXXX. Exception Cleared. Buyer Comment (2019-06-26): Econsent provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Not provided, field not shown on CD.  No cure provided for overages.

Buyer Comment (2019-06-26): XXXXXX has elected to waive this exception.

06/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901977

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower.

Missing from file.

Reviewer Comment (2019-06-27): AMC received the LE's. Buyer Comment (2019-06-26): Disclosure provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage)

XXXXXX Subprime Loan:  Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law.

Missing from file.

Reviewer Comment (2019-06-27): AMC received the LE's.

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Provide the following:  Letter of Explanation,  corrected Mortgage (with required Legend), and proof of mailing.  Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery.  Best Practice would be to have signed and re-recorded Mortgage.).

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901977

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 5.56450% or Final Disclosure APR of 5.59200% is in excess of allowable threshold of Prime Mortgage Market Rate 3.82000 + 1.75%, or 5.57000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-06-27): AMC received the LE's.

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided for overage, escrow service fee added without VCC.

Reviewer Comment (2019-06-27): AMC received SSPL dated XXXXXX. Exception Cleared. Buyer Comment (2019-06-26): See COC provided

06/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,695.00 exceeds tolerance of $1,331.00 plus 10% or $1,464.10.  Insufficient or no cure was provided to the borrower.

AMC received SSPl, E Consent, COCs and CDs. The XX06 and XX11 COC does not indicate a valid change of circumstance for the recording fee to increase. Please provide additional details or corrected CD, LOE, and refund check to cure.

Reviewer Comment (2019-06-28): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-06-28): Cure documents provided

06/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901977

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,695.00 exceeds tolerance of $1,331.00 plus 10% or $1,464.10.  Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2019-06-28): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

06/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901979

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Borrower ability to repay attestation not provided

Reviewer Comment (2019-08-01): AMC received the borrower completed and signed ATR attestation.

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Missing evidence borrower was provided the List of Homeownership Counseling Organizations at time of application.

Reviewer Comment (2019-07-02): Initial documentation provided.

07/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

Final Closing Disclosure did not disclosed number of months for Property Tax under Prepaids

Buyer Comment (2019-07-09): XXXXXX has elected to waive

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD did not reflect an amount by which the fees exceeded the legal limit.

Reviewer Comment (2019-07-08): SSPL provided - borrower shopped title fees.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Missing evidence borrower was provided the CD a minimum of 3 business days prior to closing.

Reviewer Comment (2019-07-02): Initial CD provided

07/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Loan estimate received electronically on XXXX19 which is prior to the borrowers e-consent dated XXXX19.

Reviewer Comment (2019-07-02): Initial documentation provided.

07/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on XXXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.

Loan estimate was provided to the borrower electronically prior to the borrowers consent. Disclosure will not be used for tolerance purposes and may result in disclosure timing violations

Reviewer Comment (2019-07-02): Initial documentation provided.

07/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing evidence borrower was provided the Settlement Service Provider List at time of application.

Reviewer Comment (2019-07-08): SSPL provided - borrower shopped title fees.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,706.80 exceeds tolerance of $2,430.00 plus 10% or $2,673.00.  Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance Exceeded Total amount of $1894.00 exceeds tolerance of $1441.00. No cure was provided to the borrower

Reviewer Comment (2019-07-08): SSPL provided - borrower shopped title fees. Reviewer Comment (2019-07-02): Please provide SSPL to further test tolerance exceptions.  Document has not been provided.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $181.28 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Title - Endorsement Fee amount of $181.25 exceeds tolerance ot $0.00, No cure was provided to the borrower

Reviewer Comment (2019-07-08): SSPL provided - borrower shopped title fees. Reviewer Comment (2019-07-02): Please provide SSPL to further test tolerance exceptions.  Document has not been provided.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

ARM loan program disclosure not provided to the borrower within 3 days of application

Reviewer Comment (2019-07-02): Initial documentation provided.

07/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901979

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

CHARM Booklet was provided to the borrower at time of closing vs. within 3 days of application.

Reviewer Comment (2019-07-02): Initial documentation provided.

07/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Missing Final 1003

Reviewer Comment (2019-07-09): Final 1003 provided. Buyer Comment (2019-07-09): Final 1003 uploaded

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrower had a balloon mortgage that matured which was not refinanced timely and consequently borrower received a notice of default in February XX.  Matured balloon was refinanced with bridge loan that has been paid as agreed.  Subject loan is to refinance bridge loan in to long term refinancing.  Approved Lender Exception in file.

Paying off a blanket mortgage for 3 properties that will result in an overall monthly reduction of approximately $4,000 Two closed mortgages reporting paid as agreed. Co-Borrower is XXXXXX for the past 13.4 years Credit score is 691, 51 points > program requirement of 640 LTV is 70%, 5% < program maximum of 75%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-05): Client has elected to waive this exception based on compensating factors.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow rental income per tax return Schedule E rather than leases.  Approved Lender Exception in file.

Paying off a blanket mortgage for 3 properties that will result in an overall monthly reduction of approximately $4,000 Two closed mortgages reporting paid as agreed. Co-Borrower is XXXXXX for the past 13.4 years Credit score is 691, 51 points > program requirement of 640 LTV is 70%, 5% < program maximum of 75%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-09): Client elects to waive the exception with verified compensation factors

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Updated CPA letter missing - CPA letter in file is dated XXXX18.

Reviewer Comment (2019-07-12): CPA letter provided Buyer Comment (2019-07-12): Updated CPA letter provided

07/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender acknowledged exception in file for DTI  of 53.234% however calculated DTI is 54.28394% please provide an updated exception.

Paying off a blanket mortgage for 3 properties that will result in an overall monthly reduction of approximately $4,000 Two closed mortgages reporting paid as agreed. Co-Borrower is XXXXXX for the past 13.4 years Credit score is 691, 51 points > program requirement of 640 LTV is 70%, 5% < program maximum of 75%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-18): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-18): Updated XXXXXX Credit Exception provided Reviewer Comment (2019-07-10): Pert FNMA guide, "When Schedule E is used to calculate qualifying rental income, the lender must add back any listed depreciation, interest, homeowners' association dues, taxes, or insurance expenses to the borrower's cash flow. Non-recurring property expenses may be added back, if documented accordingly.". These properties are personally owned per returns. Reviewer Comment (2019-07-08): Per REO Rent Calc Worksheet, no expenses from tax returns were taken into account. Exception remains. Buyer Comment (2019-07-05): See REO Rent Calc Worksheet provided

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - REO Schedule E Method Test

Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income (Schedule E Method) using reasonably reliable third-party records.

Lender provided the 20XXXX schedule E, however missing the signed 1040"s

Reviewer Comment (2019-07-23): AMC received the XX tax transcript with schedule E income reported. Buyer Comment (2019-07-23): XX Transcripts for both borrowers provided Reviewer Comment (2019-07-15): XX tax transcripts should be available due to the deadline for filing with extension was XXXXXX or provided signed XX tax returns. Buyer Comment (2019-07-12): Tax Transcripts provided for XX & XX. XX shows no record as they were on extension.  Please clear. Reviewer Comment (2019-07-11): Neither tax returns are signed and tax transcripts have not been provided. Buyer Comment (2019-07-10): See trailing documents re-uploaded Reviewer Comment (2019-07-10): Only XX tax returns un-signed were provided. Still need XX. Buyer Comment (2019-07-09): 1040's provided (XX & XX)

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - REO Schedule E Method Test

Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income (Schedule E Method) using reasonably reliable third-party records.

Lender provided the 20XXXX schedule E, however missing the signed 1040"s

Reviewer Comment (2019-07-23): AMC received the XX tax transcript with schedule E income reported. Buyer Comment (2019-07-23): Transcripts provided Reviewer Comment (2019-07-15): XX tax transcripts should be available due to the deadline for filing with extension was XXXXXX or provided signed XX tax returns. Buyer Comment (2019-07-12): Tax Transcripts provided for XX & XX. XX shows no record as they were on extension.  Please clear. Reviewer Comment (2019-07-11): Neither tax returns are signed and tax transcripts have not been provided. Buyer Comment (2019-07-10): XX Tax returns uploaded - see page 24-25 of trailing documents Reviewer Comment (2019-07-10): Only XX tax returns un-signed were provided. Still need XX. Buyer Comment (2019-07-09): Tax returns provided

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 54.28394% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Lender exception for DTI of 53.234% however calculated DTI is 54.28394% please provide an updated exception.

Paying off a blanket mortgage for 3 properties that will result in an overall monthly reduction of approximately $4,000 Two closed mortgages reporting paid as agreed. Co-Borrower is XXXXXX for the past 13.4 years Credit score is 691, 51 points > program requirement of 640 LTV is 70%, 5% < program maximum of 75%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-18): Client elects to waive the exception with verified compensation factors Reviewer Comment (2019-07-15): XX tax transcripts should be available due to the deadline for filing with extension was XXXXXX or provided signed XX tax returns. Buyer Comment (2019-07-12): Tax Transcripts provided for XX & XX. XX shows no record as they were on extension.  Please clear.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Reviewer Comment (2019-07-09): Disclosure tracking doc provided. Buyer Comment (2019-07-09): See Disclosure tracking provided

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Reviewer Comment (2019-07-09): Disclosure tracking doc provided. Buyer Comment (2019-07-09): See Disclosure Tracking

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Reviewer Comment (2019-07-09): Disclosure tracking doc provided. Buyer Comment (2019-07-09): See Disclosure Tracking

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Lender exception for DTI of 53.234% however calculated DTI is 54.28394% please provide an updated exception.

Reviewer Comment (2019-07-23): Lender waived the DTI exception based on compensating factors. Reviewer Comment (2019-07-23): Incorrectly waived Reviewer Comment (2019-07-18): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-18): Updated exception provided

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Lender exception for DTI of 53.234% however calculated DTI is 54.28394% please provide an updated exception.

Reviewer Comment (2019-07-18): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-18): Updated exception provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Lender exception for DTI of 53.234% however calculated DTI is 54.28394% please provide an updated exception.

Reviewer Comment (2019-07-23): AMC received the XX tax transcript with Schedule E income reported.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

Hazard insurance policy indicates premium of $3,472 annually / 12 = $289.33 per month.  Final CD indicates monthly escrow for hazard insurance of $311.00

Reviewer Comment (2019-07-09): Updated HOI policy provided. Buyer Comment (2019-07-09): See HOI provided - total policy premium is $3732 annually.  Please clear.

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Final CD issued XXXX19 was not issued at least three business days prior to closing. Actual closing date is XXXX19

Reviewer Comment (2019-07-09): Initial and interim CDs provided. Buyer Comment (2019-07-09): Initial CD provided

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $36,736.20 may be required.

File does not contain a copy of an LE

Reviewer Comment (2019-07-09): All LE's provided. Buyer Comment (2019-07-09): LE's provided

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Missing evidence borrower was provided a copy of the Servicing Disclosure at time of application.

Reviewer Comment (2019-07-09): Disclosure tracking doc provided. Buyer Comment (2019-07-09): See Disclosure tracking provided

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Allow 3 months reserves (standard) vs. program requirement of reserves increased by 6 months for Notice of Default over the past 24 months plus additional 2 months for mortgage investment property owned.  Approved Lender Exception in file.

Paying off a blanket mortgage for 3 properties that will result in an overall monthly reduction of approximately $4,000 Two closed mortgages reporting paid as agreed. Co-Borrower is XXXXXX for the past 13.4 years Credit score is 691, 51 points > program requirement of 640 LTV is 70%, 5% < program maximum of 75%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-05): Client has elected to waive this exception based on compensating factors.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Compliant Test

TIL variable rate disclosure: ARM loan program disclosure does not match terms of loan.

Reviewer Comment (2019-07-17): Disclosure provided. Buyer Comment (2019-07-16): ARM disclosure reflects 5/1 ARM which matches final CD.  Please clear.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

All tolerance violations must be addressed before this exception can be addressed.  The zero tolerance for loan discount fee increase of $4,550, Appraisal Fee increase of $150, Title - Tax Cert Fee of $450 and 10% tolerance violation for recording fee increase for $471.25.

Buyer Comment (2019-07-12): XXXXXX has elected to waive this exception.

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing Irregular Transactions

TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on XXXXXX contains a change in APR, loan product or addition of prepayment penalty and was not received by borrower at least three (3) business days prior to consummation

Interest rate on final CD issued on XXXX19 increased to 7.16% from rate on initial CD at 6.69%  Loan closed on XXXX19 which is only 2 business days after an APR change.

Reviewer Comment (2019-07-15): Additional CD's provided Buyer Comment (2019-07-12): Initial CD provided

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,076.25 exceeds tolerance of $550.00 plus 10% or $605.00.  Insufficient or no cure was provided to the borrower.

Recording fees at closing increased without an valid COC.

Reviewer Comment (2019-07-18): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-07-17): Cure documents provided Reviewer Comment (2019-07-15): AMC received CD's issued XXXXXX recording fee increased to $676.25 and CD issued XXXXXX recording fee increase to $1,076.25.  COC's provided don't specify why the recording fee increased. Additional information needed to justify fee increase or cure is due to the borrower.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $13,650.00 exceeds tolerance of $9,100.00.  Insufficient or no cure was provided to the borrower.

Initial CD issued XXXX18 disclosed Loan Discount fee of $9,100, fee increased to $13,650 without a valid COC provided.

Reviewer Comment (2019-07-15): Additional CD's provided with COC - rate re-locks Buyer Comment (2019-07-12): See COC provided dated 6/6/19

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $550.00.  Insufficient or no cure was provided to the borrower.

Appraisal fee at closing increased without an valid COC.

Reviewer Comment (2019-07-18): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-07-17): Cure documents provided - please clear. Reviewer Comment (2019-07-15): Appraisal fee increase to $700 on the XXXXXX CD no COC provided to justify fee increase.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Tax Certificate Fee.  Fee Amount of $450.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Tax Cert fee at closing increased without an valid COC.

Reviewer Comment (2019-07-15): paid to borrower chosen provider. Buyer Comment (2019-07-12): See COC provided dated XXXX19

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,076.25 exceeds tolerance of $550.00 plus 10% or $605.00.  Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2019-07-18): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $550.00.  Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2019-07-18): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901980

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Reviewer Comment (2019-07-23): AMC received the XX tax transcript with schedule E income reported.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

DTI 57.74921% > Lender approved exception of 55.118% please provide a revised Lender exception.

Reviewer Comment (2019-08-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-08-08): See trailing documents Reviewer Comment (2019-08-06): Updated qualifying rate and P&I resulted in a qualifying PITI of $10,129.57 based on a 30 yr ARM w/ a 10 yr I/O term. DTI is 59.634% Reviewer Comment (2019-08-06): Provide updated lender exception approval with updated DTI of 55.700%, due to prior lender exception approval dated XXXXXX stated to remove DTI exception. Reviewer Comment (2019-08-06): Per lender exception dated XXXXXX, DTI exception was removed. Reviewer Comment (2019-06-27): Non-QM Loan

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Qual Method differs from ATR result is Understated DTI

Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender does not adhere with ATR payment calculation methods under 1026.43(c)(5), the method rendered a DTI less than that prescribed under ATR.

Note rate +.875

Reviewer Comment (2019-08-09): Client elects to waive the exception with verified compensation factors Reviewer Comment (2019-08-06): Updated qualifying rate and P&I resulted in a qualifying PITI of $10,129.57 based on a 30 yr ARM w/ a 10 yr I/O term. DTI is 59.634% Reviewer Comment (2019-08-06): Provide updated lender exception approval with updated DTI of 55.700%, due to prior lender exception approval dated XXXXXX stated to remove DTI exception. Reviewer Comment (2019-08-06): Per lender exception dated XXXXXX, DTI exception was removed. Reviewer Comment (2019-07-12): PCCD provided. Reviewer Comment (2019-06-26): Unable to waive EV-2 exceptions.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs don't match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTIs calculated in accordance with the Lenders Guidelines of 57.74921% and based on 1026.43(c)(5) of 59.63% significantly exceed the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

DTI 57.74921% > Lender approved exception of 55.118% please provide a revised Lender exception.

Perfect credit history with never a late payment, spanning 8 mortgage accounts, with earliest inception date of XXXXXX and no public records. Borrower has been in the same line of work (XXXXXX) for the past 20 years.Co-Borrower has employment stability for 11 years in the XXXX Borrower DTI will be 42% after sale of departure property

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-09): Client elects to waive the exception with verified compensation factors Reviewer Comment (2019-08-06): Updated qualifying rate and P&I resulted in a qualifying PITI of $10,129.57 based on a 30 yr ARM w/ a 10 yr I/O term. DTI is 59.634% Reviewer Comment (2019-08-06): Provide updated lender exception approval with updated DTI of 55.700%, due to prior lender exception approval dated XXXXXX stated to remove DTI exception. Reviewer Comment (2019-08-06): Per lender exception dated XXXXXX, DTI exception was removed. Reviewer Comment (2019-06-26): Client elects to waive the exception with verified compensation factors

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901981

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender approved exception for DTI exceeding 50%, borrower intends to sell departure home after closing. DTI 57.74921% > Lender approved exception of 55.118% please provide a revised Lender exception.

Perfect credit history with never a late payment, spanning 8 mortgage accounts, with earliest inception date of XXXXXX and no public records. Perfect credit history with never a late payment, spanning 8 mortgage accounts, with earliest inception date of XXXXXX and no public records. Borrower has been in the same line of work (XXXXXX) for the past 20 years.Co-Borrower has employment stability for 11 years in the XXXX Borrower DTI will be 42% after sale of departure property Credit score of 701 is 61 points greater than required score of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-09): Client elects to waive the exception with verified compensation factors. Buyer Comment (2019-08-08): See trailing documents Reviewer Comment (2019-08-06): Updated qualifying rate and P&I resulted in a qualifying PITI of $10,129.57 based on a 30 yr ARM w/ a 10 yr I/O term. DTI is 59.634% Reviewer Comment (2019-08-06): Provide updated lender exception approval with updated DTI of 55.700%, due to prior lender exception approval dated XXXXXX stated to remove DTI exception. Reviewer Comment (2019-08-06): Per lender exception dated XXXXXX, DTI exception was removed. Reviewer Comment (2019-06-26): Client elects to waive the exception with verified compensation factors. Buyer Comment (2019-06-25): Updated Approved XXXXXX Credit Exception Revision provided. Reviewer Comment (2019-06-19): No updated information was located for this exception. Condition remains. Reviewer Comment (2019-06-18): Corrected qualifying rate per worksheet provided. Updated DTI is 55.700% vs 55.118%. Difference due to REOI section on final 1003 reflects for primary residence -$4421.00, which is missing the HOA pmnt, should be -$4600.00. Buyer Comment (2019-06-17): Correct Note term / Amort schedule is 480 months (see rate lock provided).  Corrected Note requested.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

ATR risk due to DTI exceeding 50%. DTI 57.74921% > Lender approved exception of 55.118% please provide a revised Lender exception.

Reviewer Comment (2019-08-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-08-08): See trailing documents Reviewer Comment (2019-08-06): Updated qualifying rate and P&I resulted in a qualifying PITI of $10,129.57 based on a 30 yr ARM w/ a 10 yr I/O term. DTI is 59.634% Reviewer Comment (2019-08-06): Provide updated lender exception approval with updated DTI of 55.700%, due to prior lender exception approval dated XXXXXX stated to remove DTI exception. Reviewer Comment (2019-08-06): Per lender exception dated XXXXXX, DTI exception was removed. Reviewer Comment (2019-06-26): Client elects to waive the exception with verified compensation factors

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The final CD disclosed the closing date as XXXX19.  One of the borrowers signed on XXXX19.

Buyer Comment (2019-06-26): XXXXXX has elected to waive this exception.

06/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Qualifying interest rate discrepancy.

Reviewer Comment (2019-06-18): Qualifying rate worksheet provided. Buyer Comment (2019-06-17): See trailing documents

06/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Qual Method differs from ATR, DTI is not Understated

Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender does not match the ATR payment calculation methods under 1026.43(c)(5), but the method did not render a DTI that is less than that prescribed under ATR.

Reviewer Comment (2019-08-06): Corrected loan terms to 30 year ARM I/O with 30 year amort. per lender.

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 55.70052% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Perfect credit history with never a late payment, spanning 8 mortgage accounts, with earliest inception date of XXXXXX and no public records. Perfect credit history with never a late payment, spanning 8 mortgage accounts, with earliest inception date of XXXXXX and no public records. Borrower has been in the same line of work (XXXXXX) for the past 20 years.Co-Borrower has employment stability for 11 years in the XXXX Borrower DTI will be 42% after sale of departure property Credit score of 701 is 61 points greater than required score of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-09): erro Reviewer Comment (2019-08-09): Client elects to waive the exception with verified compensation factors Reviewer Comment (2019-08-06): Updated qualifying rate and P&I resulted in a qualifying PITI of $10,129.57 based on a 30 yr ARM w/ a 10 yr I/O term. DTI is 59.634% Reviewer Comment (2019-08-06): Provide updated lender exception approval with updated DTI of 55.700%, due to prior lender exception approval dated XXXXXX stated to remove DTI exception. Reviewer Comment (2019-08-06): Per lender exception dated XXXXXX, DTI exception was removed. Reviewer Comment (2019-07-12): Client has elected to waive this exception based on compensating factors. Buyer Comment (2019-07-12): XXXXXX Approved Credit Exception Uploaded

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Amount Financed

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed an Amount Financed that was not within tolerance of the actual amount financed for the loan.

.

Reviewer Comment (2019-08-06): Corrected loan terms to 30 year ARM I/O with 30 year amort. per lender. Buyer Comment (2019-08-05): XXXXXX update to credit loan program - see trailing documents Reviewer Comment (2019-07-17): AMC received copy of initial CD.  Testing is completed off final CD.  Exception stands. Reviewer Comment (2019-07-15): Per compliance dept., CD was disclosed with values based on a 30 year term, if loan closed with 40 year term, the result is a $xxx TOP variance and xxxx finance charge under disclosure. To cure, an LOE, refund/adjustment in the amount of xxxx to ensure the borrower does not pay more than what was disclosed, corrected PC-CD, and proof of receipt all within 60 days of discovery is required to cure. Reviewer Comment (2019-07-12): CD was disclosed with values based on a 30 year term, if loan closed with 40 year term, the result is a $xxxx TOP variance and $xxxx finance charge under disclosure. To cure, an LOE, refund/adjustment in the amount of xxxx to ensure the borrower does not pay more than what was disclosed, corrected PC-CD, and proof of receipt all within 60 days of discovery is required to cure. Buyer Comment (2019-07-12): See trailing documents

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AP Table Maximum Payment

TILA-RESPA Integrated Disclosure - Adjustable Payment Table: Final Closing Disclosure provided on XXXXXX disclosed a Maximum Payment amount and period that does not match the actual terms for the loan.

.

Reviewer Comment (2019-07-12): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-07-12): PCCD and LOE provided

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

.

Reviewer Comment (2019-08-06): Corrected loan terms to 30 year ARM I/O with 30 year amort. per lender. Buyer Comment (2019-08-05): See trailing documents Reviewer Comment (2019-07-15): Per compliance dept., CD was disclosed with values based on a 30 year term, if loan closed with 40 year term, the result is a $xxxx TOP variance and $xxxx finance charge under disclosure. To cure, an LOE, refund/adjustment in the amount of $xxxx to ensure the borrower does not pay more than what was disclosed, corrected PC-CD, and proof of receipt all within 60 days of discovery is required to cure. Reviewer Comment (2019-07-12): CD was disclosed with values based on a 30 year term, if loan closed with 40 year term, the result is a $xxxx TOP variance and $xxx finance charge under disclosure. To cure, an LOE, refund/adjustment in the amount of $xxxx to ensure the borrower does not pay more than what was disclosed, corrected PC-CD, and proof of receipt all within 60 days of discovery is required to cure. Buyer Comment (2019-07-12): See trailing documents

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Loan Term

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Loan Term that does not match the actual loan term for the loan.

.

Reviewer Comment (2019-07-12): Letter of Explanation, Proof of Delivery, Corrected CD provided Buyer Comment (2019-07-12): See trailing documents

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Payment Max Amount

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on XXXXXX with an increasing payment disclosed the maximum possible amount of principal and interest that does not match the actual maximum amount for the loan.

.

Reviewer Comment (2019-07-12): Letter of Explanation, Proof of Delivery, Corrected CD provided Buyer Comment (2019-07-12): See trailing documents

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

.

Reviewer Comment (2019-07-12): Letter of Explanation, Proof of Delivery, Corrected CD provided Buyer Comment (2019-07-12): See trailing documents

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total of Payments that does not match the actual total of payments for the loan.

.

Reviewer Comment (2019-08-06): Corrected loan terms to 30 year ARM I/O with 30 year amort. per lender. Buyer Comment (2019-08-05): See trailing documents Reviewer Comment (2019-07-15): Per compliance dept., CD was disclosed with values based on a 30 year term, if loan closed with 40 year term, the result is a $xxx TOP variance and $xxx finance charge under disclosure. To cure, an LOE, refund/adjustment in the amount of $xxx to ensure the borrower does not pay more than what was disclosed, corrected PC-CD, and proof of receipt all within 60 days of discovery is required to cure. Reviewer Comment (2019-07-12): CD was disclosed with values based on a 30 year term, if loan closed with 40 year term, the result is a $xxxx TOP variance and xxxx finance charge under disclosure. To cure, an LOE, refund/adjustment in the amount of $xxxx to ensure the borrower does not pay more than what was disclosed, corrected PC-CD, and proof of receipt all within 60 days of discovery is required to cure. Buyer Comment (2019-07-12): See trailing documents

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901981

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Provide lender exception approval for loan to close as XX1 ARM I/O with a 30 year amort term vs  40 year loan term on I/O loans. Also DTI exception for 55.700% to be added. Cannot change loan program to A6 Asset Depletion post close. Program to remain SP J8 Jumbo Prime, Full Doc.

Reviewer Comment (2019-08-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-08-08): Updated Approved Credit Exception, 1008 Transmittal, Revised Loan Approval  and Rate Lock uploaded for review. Reviewer Comment (2019-08-06): Updated qualifying rate and P&I resulted in a qualifying PITI of $10,129.57 based on a 30 yr ARM w/ a 10 yr I/O term. DTI is 59.634%

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901982

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Aged document: Asset Account date is more than 90 days prior to the note.

- Asset Account Date: ___

XXXXXX is 91 days at time of Note date. London Life is only issued on a semi-annual period next statement XXXXXX.

Reviewer Comment (2019-06-11): AMC received the 4/XXXX statement.

06/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901982

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.73030% or Final Disclosure APR of 6.94900% is in excess of allowable threshold of APOR 4.18% + 1.5%, or 5.68000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-06-03): XXXXXX mortgage purXXXXXXs HPML compliant loans.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901982

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

A CPA letter was required confirming the Borrower's percentage of ownership in business, however, it could not be found in file.

Reviewer Comment (2019-06-21): CPA letter provided.

06/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901982

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

The copy of the appraisal was provided to the Borrower after the effective date but prior to the report date.

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901982

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Provide additional assets for funds to close.

Reviewer Comment (2019-06-28): Based on 401k with xxxx for closing at 60%. Reviewer Comment (2019-06-25): Per final 1003, XXXXXX is being used for closing funds, however no statements provided in file. Short to close $55,633.56

06/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901982

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue:Insufficient asset documentation.

-

Statement provided is not consecutive, 4 month gap between most recent statement and the original statement provided.

Reviewer Comment (2019-06-11): Statement is semi-annual.

06/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901982

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Missing Document: Asset Documentation not provided

Missing page 2 of most recent statement provided for XXXXXX dated XXXXXX.

Reviewer Comment (2019-08-02): Pages 1-2 provided. Reviewer Comment (2019-06-25): Per mngt, since asset document for XXXXXX reflects 2 pages, both are required.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207901983

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML) California Higher-Priced Mortgage Loan (APR Exceeds HPML Threshold)

XXXXXX Higher-Priced Loan: APR on subject loan of 7.31890% or Final Disclosure APR of 7.32500% is in excess of allowable threshold of APOR 4.66% + 2.5%, or 7.16000%.  Compliant Higher Priced Loan.

Reviewer Comment (2019-06-06): Client purXXXXXXs HPML compliant loans.

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901983

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing bank statements for account XXXXXX  as well as November XX and December XX bank statements for XXXXXX  used for qualifying based on Lender approval and income worksheet.

Reviewer Comment (2019-07-03): Updated banks statement income. Buyer Comment (2019-07-03): Please see FINAL INCOME CALC  and Bank Statements for account XXXXXX NovXX-April XX and bank statements for account XXXXXX May XX through Oct XX; The borrower switched business account from XXXXXX starting in November of XX as deposits will show on the Final income calc Reviewer Comment (2019-06-14): Clarification we are requesting : Missing months 2/18,3/18,4/18,XX18 for account XXXXXX with XXXXXX. Missing months XX18 and XX18 for account XXXXXX with XXXXXX. Reviewer Comment (2019-06-10): To confirm:  The file is missing the following bank statements: Account XXXXXX XXXXXX, XXXXXX, XXXXXX and account XXXXXX XXXXXX & XXXXXX. Buyer Comment (2019-06-07): please confirm which months bank statements you are requesting for acct XXXX

07/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901983

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.31890% or Final Disclosure APR of 7.32500% is in excess of allowable threshold of APOR 4.66% + 2.5%, or 7.16000%.  Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-06-06): Client purXXXXXXs HPML compliant loans.

06/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901983

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

DTI of 49% exceeds max 43% allowed.  Approved Lender Exception in file for DTI of 45.129 please provide bank statements for review for a revised DTI and if remains above 45.129% a revised Lender exception.

Reviewer Comment (2019-07-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-09): Please see revised exception approval Reviewer Comment (2019-07-03): Updated bank statement income calc. DTI is 46.046%. Buyer Comment (2019-07-03): Please see FINAL INCOME CALC  and Bank Statements for account XXXXXX NovXX-April XX and bank statements for account XXXXXX May XX through Oct XX; The borrower switched business account from XXXXXX to NXXXXXX starting in November of XX as deposits will show on the Final income calc - docs previously uploaded

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901983

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 49.83376% significantly exceeds the guideline maximum of 43.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

DTI of 49% exceeds max 43% allowed.  Approved Lender Exception in file for DTI of 45.129 please provide bank statements for review for a revised DTI and if remains above 45.129% a revised Lender exception.

Reviewer Comment (2019-07-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-09): Please see revised exception approval Reviewer Comment (2019-07-03): Updated bank statement income calc. DTI is 46.046%. Buyer Comment (2019-07-03): Please see FINAL INCOME CALC  and Bank Statements for account XXXXXX NovXX-April XX and bank statements for account XXXXXX May XX through Oct XX; The borrower switched business account from XXXXXX to NXXXXXX starting in November of XX as deposits will show on the Final income calc - docs previously uploaded

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901983

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

DTI of 49.83376% exceeds max 43% allowed per guidelines.  Approved Lender Exception in file of DTI of 45.129 please provide bank statements for review for a revised DTI and if remains above 45.129% a revised Lender exception..

Borrower has a perfect credit history since inception of earliest account opened XXXXXX.  No public records. Borrower has employment stability for 10 years - XXXXXX Credit score is 713, 33 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-09): Please see revised exception approval Reviewer Comment (2019-07-03): Updated bank statement income calc. DTI is 46.046%. Buyer Comment (2019-07-03): Please see FINAL INCOME CALC  and Bank Statements for account XXXXXX NovXX-April XX and bank statements for account XXXXXX May XX through Oct XX; The borrower switched business account from XXXXXX to NXXXXXX starting in November of XX as deposits will show on the Final income calc - docs previously uploaded

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901983

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

49% DTI exceeds max of 43% allowed.  Approved Lender Exception in file of  DTI of 45.129 please provide bank statements for review for a revised DTI and if remains above 45.129% a revised Lender exception..

Reviewer Comment (2019-07-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-09): Please see revised exception approval Reviewer Comment (2019-07-03): Updated bank statement income calc. DTI is 46.046%. Buyer Comment (2019-07-03): Please see FINAL INCOME CALC  and Bank Statements for account XXXXXX NovXX-April XX and bank statements for account XXXXXX May XX through Oct XX; The borrower switched business account from XXXXXX to NXXXXXX starting in November of XX as deposits will show on the Final income calc - docs previously uploaded

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901983

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

CPA will not provide letter stating use of funds will not have a negative effect on business vs program requirement if using business funds to close/or reserves, a CPA letter must accompany the file stating that use of business funds will not negatively affect the business. Lender acknowledged.

Borrower has a perfect credit history since inception of earliest account opened XXXXXX.  No public records. Borrower has employment stability for 10 years - XXXXXX Credit score is 713, 33 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-06-06): Client has elected to waive this exception based on compensating factors.

06/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901983

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 46.04626% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower has a perfect credit history since inception of earliest account opened XXXXXX.  No public records. Borrower has employment stability for 10 years - XXXXXX Credit score is 713, 33 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-09): Client elects to waive the exception with verified compensation factors

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.92710% or Final Disclosure APR of 6.96300% is in excess of allowable threshold of Prime Mortgage Market Rate 4.10000 + 1.75%, or 5.85000%.  Non-Compliant SubPrime Loan.

Final Disclosure APR of 6.96300% exceeds the Prime Mortgage Market Rate of 6.56000%

Reviewer Comment (2019-07-31): AMC received the re-recording of the security instrument with reason for re-recording of additional language being XXXXXX subprime loan. Reviewer Comment (2019-07-22): Missing the Subprime legend on the Security Agreement.

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $52,970.63 and disclosure timing violations.

E-sign consent form not on file. Disclosures sent electronically may result in a fee tolerance violation of up to $51,222.54.

Reviewer Comment (2019-06-03): AMC received required documents, exception is cleared.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided an incorrect amount that eh Total Closing Costs exceeded the legal limit

Reviewer Comment (2019-06-03): AMC received required documents, exception is cleared.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan  Toolkit Disclosure not provided to Borrower

Reviewer Comment (2019-06-04): Disclosure summary provided. Reviewer Comment (2019-06-03): Disclosure summary shows document received, but document is required in order to compare data points from document.

06/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided at least 3 days prior to closing

Reviewer Comment (2019-06-03): AMC received required documents, exception is cleared.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Borrower not provided a list of service providers

Reviewer Comment (2019-06-03): AMC received required documents, exception is cleared.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search.  Fee Amount of $425.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Title Search fee amount of $425 exceeds tolerance of $0.00. No cure was provided to the borrower.

Reviewer Comment (2019-06-03): AMC received required documents, exception is cleared.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Services Sales Tax.  Fee Amount of $43.58 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Title Services Sales Tax Fee amount of $43.58 exceeds tolerance of $0.00. No cure was provided to the borrower

Reviewer Comment (2019-06-03): AMC received required documents, exception is cleared.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXXX exceeds tolerance of $28,889.00.  Insufficient or no cure was provided to the borrower.

Transfer Tax Fee amount of $xxxx exceeds tolerance of $xxxx. No cure was provided to the borrower.  Initial LE was e-signed and no e-consent provided for allowance of baseline.

Reviewer Comment (2019-06-03): AMC received required documents, exception is cleared.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.

Affiliated Business Arrangement Disclosure not provided to Borrower within 3 business days of application

Reviewer Comment (2019-06-03): AMC received required documents, exception is cleared.

06/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Borrower did not receive a List of Homeownership Counseling Organizations

Reviewer Comment (2019-06-04): Disclosure summary provided. Reviewer Comment (2019-06-03): Disclosure summary shows document received, but document is required in order to compare data points from document.

06/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower.

Counseling Disclosure not provided ti the borrower

Reviewer Comment (2019-07-22): AMC received the NY Subprime counseling disclosure.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901984

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage)

XXXXXX Subprime Loan:  Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law.

Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Lay of XXXXXX

Reviewer Comment (2019-07-31): AMC received the re-recording of the security instrument with reason for re-recording of additional of the following language being XXXXXX subprime loan.

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Provide the following:  Letter of Explanation,  corrected Mortgage (with required Legend), and proof of mailing.  Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery.  Best Practice would be to have signed and re-recorded Mortgage.).

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901984

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.92710% or Final Disclosure APR of 6.96300% is in excess of allowable threshold of Prime Mortgage Market Rate 4.81000 + 1.75%, or 6.56000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-31): XXXXXX has elected to waive

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901985

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

There were multiple fee tolerance violations and the cure amount of $50, disclosed on the final CD, is an inaccurate value.

Reviewer Comment (2019-07-08): COC - loan amount increase and  $50.00 cure provided at closing. Buyer Comment (2019-07-08): Final CD reflects cure

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901985

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXXX exceeds tolerance of $13,500.00.  Insufficient or no cure was provided to the borrower.

The Mortgage Broker Fee increased prior to the initial rate lock with no valid changed circumstance or cure provided to Borrower.

Reviewer Comment (2019-07-08): COC - loan amount increase.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901985

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $800.00 exceeds tolerance of $750.00.  Insufficient or no cure was provided to the borrower.

The appraisal fee increased with no valid changed circumstance or cure provided to the Borrower.

Reviewer Comment (2019-07-08): $50.00 cure provided at closing. Buyer Comment (2019-07-08): Final CD reflects cure

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901985

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

The valuations were provided to the Borrower after the effective dates but prior to the report dates.

Buyer Comment (2019-07-08): waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901985

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA LO Compensation (Impermissible Compensation Method)

Loan Originator Compensation (Dodd-Frank 2014):  Unable to determine Compensation method used.

The disclosure provided the compensation figure but does not indicate the method in which was determined.

Buyer Comment (2019-07-08): waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901985

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $800.00 exceeds tolerance of $750.00.  Sufficient or excess cure was provided to the borrower at Closing.

$50.00 cure provided at closing.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901986

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901986

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

The initial CD was provided on XXXX19 with no evidence of early receipt; the borrower signed on XXXX19.

Reviewer Comment (2019-07-11): AMC received disclosure tracking indicating XX25 CD was received the same day. Exception Cleared. Buyer Comment (2019-07-10): See evidence of receipt of CD

07/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901986

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

The Compliance Report was not provided.

Reviewer Comment (2019-07-11): Compliance Report was provided.

07/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901987

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207901987

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception. Borrower was previously a self-employed contractor (1099) for XXXXXX prior to starting XXXXXX  15 months ago on XXXXXX vs program requirement of 24 months continuous self-employment.

25.51069% DTI  < 43% guideline max Reserves are 25.69 months > program requirement of 3 months Credit score is 739 > program requirement of 680 LTV is 70%, 20% < program maximum of 90%. Borrower has been self employed for the past 4 years and was previously a XXXXXX prior to becoming self employed 15 months ago as XXXXXX

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-05): Client has elected to waive this exception based on compensating factors.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207901988

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

High Cost Indicator Test

Loan does not exceed any high cost thresholds, however, documentation indicating loan was originated as a high cost loan found in file.

Mavent in file shows high cost failure. However, subject loan is an investment property, not subject to HOEPA or state high cost testing.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

N/A

N/A

No

207901988

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Missing

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to consumer.

Missing from file.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

N/A

N/A

No

207901989

XXXXXX

XXXXXX

Credit

Credit

Public Records

Public Records/Collections/Charge Off does not meet guidelines.

-

Subject property has a Lis Pendens filed XXXXXX due to Mechanic's Lien that will be paid off with this transaction, borrower also has a foreclosure completed XXXXXX (32 months) vs program requirement of no foreclosure, bankruptcy, deed in lieu or short sale over the past 48 months at standard LTVs and reserves.

Reserves are 118 months, 109 months > program requirement of 110% of the loan + 9 months PITI. DTI is 31.516%; 18.484% < program maximum of 50%. FICO 713, 33 points > 680 program requirement.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-05): Client has elected to waive this exception based on compensating factors.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901989

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/XXXX 12:00:00 AM was received.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901989

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/XXXX 12:00:00 AM was received.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901989

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Minimum Loan Amount discrepancy.

Note loan amount of ___ is less than Guideline minimum loan amount of ___.

Loan amount does not meet guideline minimum.

Reserves are 118 months, 109 months > program requirement of 110% of the loan + 9 months PITI. DTI is 31.516%; 18.484% < program maximum of 50%. FICO 713, 33 points > 680 program requirement.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-10): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-09): Please see the uploaded exception which has a counter offer of $145,000 max loan amount. Reviewer Comment (2019-07-08): Page 39 reflects Owner Occ and second homes, minimum loan amount is $150,000.00. Buyer Comment (2019-07-08): The borrower's credit score is 713 and per A6 matrix, page 34 for primary, there is no minimum loan amount. Primary Residence - 1 - 4 Unit and Condo FOR CREDIT SCORES OF LESS THAN 650, the minimum loan is $150,000.

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207901990

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Report was not provided.

Reviewer Comment (2019-07-10): Compliance Report was provided. Buyer Comment (2019-07-09): Mavent provided

07/10/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

B

B

C

B

A

A

N/A

N/A

Yes

207901990

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender exception provided for DTI exceeding program maximum.

Two closed mortgages reporting paid as agreed. Paying off a blanket mortgage for 3 properties that will result in an overall monthly reduction of approximately $4,000. Co-borrower is XXXXXX for the past 10 years. Credit score is 691, 31 points > program requirement of 660.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-08): Client has elected to waive this exception based on compensating factors.

07/08/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

B

B

C

B

A

A

N/A

N/A

No

207901990

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Buyer Comment (2019-07-09): XXXXXX has elected to waive this exception.

07/09/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

B

B

C

B

A

A

N/A

N/A

No

207901990

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Missing

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to consumer.

Buyer Comment (2019-07-09): XXXXXX has elected to waive this exception.

07/09/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

B

B

C

B

A

A

N/A

N/A

No

207901990

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Housing history reflects lates that do not meet guidelines

Borrower had a balloon mortgage that matured which was not refinanced timely and consequently borrower received a notice of default in February XX.  Matured balloon was refinanced with bridge loan that has been paid as agreed.  Subject loan is to refinance bridge loan into long term financing.

Two closed mortgages reporting paid as agreed. Paying off a blanket mortgage for 3 properties that will result in an overall monthly reduction of approximately $4,000. Co-borrower is XXXXXX for the past 10 years. Credit score is 691, 31 points > program requirement of 660.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-08): Client has elected to waive this exception based on compensating factors.

07/08/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

B

B

C

B

A

A

N/A

N/A

No

207901990

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

Insufficient Verification of Rental History.

Allow rental income per tax return Schedule E rather than leases.

Two closed mortgages reporting paid as agreed. Paying off a blanket mortgage for 3 properties that will result in an overall monthly reduction of approximately $4,000. Co-borrower is XXXXXX for the past 10 years. Credit score is 691, 31 points > program requirement of 660.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-08): Client has elected to waive this exception based on compensating factors.

07/08/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

B

B

C

B

A

A

N/A

N/A

No

207901990

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Mortgagee on dec page shows lender name only, missing ISAOA.

Reviewer Comment (2019-07-16): Hazard Insurance policy does not list "Lender its successors and assigns", provided. Buyer Comment (2019-07-16): Updated HOI provided

07/16/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

B

B

C

B

A

A

N/A

N/A

No

207901991

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing from file.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207901991

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.71150% or Final Disclosure APR of 7.72900% is in excess of allowable threshold of Prime Mortgage Market Rate 3.99000 + 1.75%, or 5.74000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207901992

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Representative FICO score of ___ is less than Guideline representative FICO score of ___.

Credit score is 643 vs. program requirement of 660 for 90% LTV.  Approved Lender Exception in file.

VOR reflects 0x30 since inception XXXXXX. 5 closed mortgages reflect paid as agreed. No public records. Borrower has been in same line of business for the past 3 years. DTI is 35.57941%, 7.42059% < program max of 43%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-08): Client has elected to waive this exception based on compensating factors.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207901992

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided a copy of the LO Compensation Disclosure at time of application.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207901992

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Missing evidence borrower was provided a copy of the Anti Steering Disclosure at time of application.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207901993

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charged under disclosed by -$110.00. $110.00 finance charge variance (condo questionnaire).

Reviewer Comment (2019-07-16): Letter of Explanation, Proof of Delivery, Refund check for under disclosed amount, Corrected CD provided Reviewer Comment (2019-07-09): Generally a Condo Questionaire is a lender requirement to do the loan and would be a finance charge fee.  If the Lender nor the title required the questionaire it can be omitted from testing.  Please provide an attestation for the actual purpose of the fee or a corrected CD, copy of refund check, letter of explanation and proof of delivery to cure. Buyer Comment (2019-07-09): per compliance report the condo questionnaire fee should not be included in the finance charge

07/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901993

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Non-escrowed HOA dues shown as $300 on final CD and 1003, however appraisal shows $1068.00 monthly.

Reviewer Comment (2019-07-16): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-07-15): uploaded pccd

07/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901993

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Approved lender exception doc 7 for condo project having current pending litigation as defendant (Master condo insurance company denied coverage on litigation) vs. program restriction that no current pending condo litigation on the subject project.

Perfect credit history with never a late payment, spanning 2 mortgage accounts, with earliest account inception date of XXXXXX and no public records. Borrower has been XXXXXX for the past 2 years and has been in same line or work for the past 25 years. 7% DTI vs. program max 43%. 23 months reserves vs. program required 5 months. 735 credit score vs. program min. 680. Long established condo project, no single entity owns 15%, no commercial space, overall project delinq. is 0%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-08): Client has elected to waive this exception based on compensating factors.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901993

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Evidence if/when preliminary report was provided to borrower missing from file.

Reviewer Comment (2019-07-09): Appraisal receipt provided. Buyer Comment (2019-07-09): uploaded appraisal confirmation and acknowledgement

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901993

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.41330% or Final Disclosure APR of 7.42000% is in excess of allowable threshold of APOR 4.56% + 1.5%, or 6.06000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-09): Appraisal receipt provided. Buyer Comment (2019-07-09): uploaded appraisal confirmation and acknowledgement

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901993

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Evidence if/when preliminary report was provided to borrower missing from file.

Reviewer Comment (2019-07-09): Appraisal receipt provided.

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901993

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $520.00 exceeds tolerance of $475.00.  Sufficient or excess cure was provided to the borrower at Closing.

$45.00 cure provided for this overage, appraisal fee increased without VCC.

07/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901993

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Reviewer Comment (2019-07-09): Effective date is XXXXXX

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901994

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

The file is missing documentation to verify the Loan Originator Compensation was not based on a term of the transaction.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901994

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charge under disclosed by $75.08, a Title Sub Escrow fee of $75.00 appears on the final disclosure for the first time in section C

Reviewer Comment (2019-07-17): Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission provided. Buyer Comment (2019-07-16): RTC expired 7/15 Reviewer Comment (2019-07-10): RTC received and expires on 7/15.  Exception will be cured on 7/16. Reviewer Comment (2019-07-09): Received PCCD, LOE, Proof of Delivery and copy of check.  Rescission must be reopened and proof of such id required in order to address the exception.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901994

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Homeowner's insurance under Prepaids reflects $472 for 12 months. The actual premium is $8,660 for a monthly payment of $721.67.

Reviewer Comment (2019-07-09): AMC received Letter of Explanation & Corrected Closing Disclosure. Buyer Comment (2019-07-08): uploaded pccd

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901994

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Lender approved exception to allow LTV of 75% vs program max of 70%

Borrower has perfect credit history since inception of earliest account dated XXXXXX No public records. Borrower is self-employed for 7.79 years as XXXXXX 34.04% DTI < 50% guideline max FICO is 714 > program requirement of 700

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-05): Client has elected to waive this exception based on compensating factors.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901995

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

38.749% DTI on this bank statement documentation loan < 50% guideline max - 11.251% below program guideline maximum FICO is 656, 13 points > program requirement of 640 Paying off subject private balloon mtg of XXXXXX

Originator Originator Originator

Reviewer Comment (2019-07-17): Client elects to waive the exception with verified compensation factors

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901995

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-07-11): AMC received the XXXXXX 2200 6/XX19 statement.

07/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901995

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

CPA letter or other documentation to prove Co-Borrower has ownership in Borrower's Business

Reviewer Comment (2019-07-12): Co-borrower is not S/E employed, require wage earner documentation. Buyer Comment (2019-07-11): Co-borrower has no shares, just a member Reviewer Comment (2019-07-11): Exception is for co-borrower. CPA letters provided are for primary borrower.

07/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901995

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

File is missing evidence that CoBorrower owns part of Borrower's business in order to use the Bank Statement Deposits of her account as income.

Reviewer Comment (2019-07-17): CPA letter provided. Buyer Comment (2019-07-16): his is a bank statement loan and we have license from the state of XXXXXX website.  Shows active and for more than 2 years Reviewer Comment (2019-07-12): Co-borrower is not S/E employed, require wage earner documentation. Buyer Comment (2019-07-11): Co-borrower has no shares, just a member Reviewer Comment (2019-07-11): Exception is for co-borrower. CPA letters provided are for primary borrower. Buyer Comment (2019-07-11): Please see CPA letter

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207901995

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - Bank Statements

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current employment status using reasonably reliable third-party records.

File is missing evidence that CoBorrower owns part of Borrower's business in order to use the Bank Statement Deposits of her account as income.

Reviewer Comment (2019-07-17): CPA letter provided. Buyer Comment (2019-07-16): Please see uploaded CPA  letter Reviewer Comment (2019-07-12): Co-borrower is not S/E employed, require wage earner documentation. Buyer Comment (2019-07-11): Co-borrower has no shares, just a member Reviewer Comment (2019-07-11): Exception is for co-borrower. CPA letters provided are for primary borrower. Buyer Comment (2019-07-11): Please see CPA letter

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901995

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

File is missing evidence that CoBorrower owns part of Borrower's business in order to use the Bank Statement Deposits of her account as income.

Reviewer Comment (2019-07-17): CPA letter provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901995

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 8.12140% or Final Disclosure APR of 8.14000% is in excess of allowable threshold of Prime Mortgage Market Rate 4.10000 + 1.75%, or 5.85000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-11): XXXXXX has elected to waive

07/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901995

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Co-borrower is not S/E employed, can not use bank statement income for wage earner. Provide all applicable wage earner documentation for review.

Reviewer Comment (2019-07-17): CPA letter provided. Buyer Comment (2019-07-16): Please see uploaded documents

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207901996

XXXXXX

XXXXXX

Credit

Property - Appraisal

General Appraisal Requirements

Subject is a refinance and property is listed for sale.

Lender acknowledged exception to allow subject that was listed for sale over the past three months (Listed on XXXX19 and Temp Off Market as of XXXX19) vs. program requirement that the Subject Property has not been listed for sale, and my not have been listed for sale during the 3 month period preceding the date of the loan

Perfect credit history since inception of earliest account opened XXXXXX, No public records. Subject property owned free and clear prior to current loan DTI is 10.48649%, 39.51351% < program maximum of 50%. 1016 months reserves > 864 months guideline minimum - borrowers have verified reserves of 110% + 3 months + 2 months for one mortgaged investment property Credit score is 801, 121 points > program requirement of 680

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-05): Client has elected to waive this exception based on compensating factors.

07/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901996

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-15): Receipt of appraisal provided. Reviewer Comment (2019-07-09): Exception is in regards to the document signed AT CLOSING acknowledging receipt of appraisal. Document provided in trailing docs is from initial application date.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901996

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.87570% or Final Disclosure APR of 5.87600% is in excess of allowable threshold of APOR 3.87% + 1.5%, or 5.37000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-17): Receipt of Appraisal provided. Reviewer Comment (2019-07-15): Still need document signed AT CLOSING acknowledging receipt of appraisal. Reviewer Comment (2019-07-09): Exception is in regards to the document signed AT CLOSING acknowledging receipt of appraisal. Document provided in trailing docs is from initial application date. Buyer Comment (2019-07-08): uploaded appraisal acknowledgement

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901996

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-15): Receipt of appraisal provided. Reviewer Comment (2019-07-09): Exception is in regards to the document signed AT CLOSING acknowledging receipt of appraisal. Document provided in trailing docs is from initial application date. Buyer Comment (2019-07-08): uploaded appraisal acknowledgement

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901996

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901996

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Subject loan is a fixed rate without Assumption clause. Final CD indicated loan is assumable.

Buyer Comment (2019-07-08): waive

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901996

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-17): Receipt of Appraisal provided. Reviewer Comment (2019-07-09): Exception is in regards to the document signed AT CLOSING acknowledging receipt of appraisal. Document provided in trailing docs is from initial application date. Buyer Comment (2019-07-08): uploaded appraisal acknowledgement

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901996

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-17): Receipt of Appraisal provided. Reviewer Comment (2019-07-09): Exception is in regards to the document signed AT CLOSING acknowledging receipt of appraisal. Document provided in trailing docs is from initial application date. Buyer Comment (2019-07-08): uploaded appraisal acknowledgement

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901996

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Reviewer Comment (2019-07-15): Effective date is XXXXXX

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901997

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901997

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Reviewer Comment (2019-07-12): Tolerance exceptions are addressed. Exception Cured.

07/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901997

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXXX exceeds tolerance of $10,969.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $11,407.50 exceeds tolerance of $10,969.00.  Missing proof of valid change, insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-07-10): COC - loan amount increase Buyer Comment (2019-07-09): Uploaded For Review-COC

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901997

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $505.00 exceeds tolerance of $500.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $505.00 exceeds tolerance of $500.00.  Missing proof of valid change, insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-07-12): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-07-11): Uploaded For Review-PCCD Docs

07/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901997

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Section F of final disclosure reflects 2 months of homeowners insurance pre paid at $374.40, does not match the monthly calculation

Reviewer Comment (2019-07-12): AMC received PCCD correcting HOI months and LOE. Exception Cured.

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901997

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender approved exception for DTI exceeding 43% at 45.186% program maximum at 90% LTV

Subject phase is complete and meets warrant able condo project requirements. 2 closed mortgages perfectly paid with earliest inception date 4/2005. Borrower has self-employed as owner of XXXXXX for the past 6 years Credit score is 694, 14 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-08): Client has elected to waive this exception based on compensating factors.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901997

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 44.05272% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Subject phase is complete and meets warrant able condo project requirements. 2 closed mortgages perfectly paid with earliest inception date 4/2005. Borrower has self-employed as owner of XXXXXX for the past 6 years Credit score is 694, 14 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-08): Client has elected to waive this exception based on compensating factors.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901997

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow rental income per lease agreement as only a portion of rents received on a investment property can be documented which is paid by Section 8 Housing and a portion is paid in cash by tenant by program restriction that rents received in cash are not allowed.

Subject phase is complete and meets warrant able condo project requirements. 2 closed mortgages perfectly paid with earliest inception date 4/2005. Borrower has self-employed as owner of XXXXXX for the past 6 years Credit score is 694, 14 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-08): Client has elected to waive this exception based on compensating factors.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207901997

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $505.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower.

AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-07-12): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207901998

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207901998

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Loan product is a fixed rate which is not assumable. Final CD indicates loan is assumable.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901998

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Processing Fee.  Fee Amount of $695.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207901998

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

The Compliance Report was not provided.

Reviewer Comment (2019-07-09): Compliance Report was provided. Buyer Comment (2019-07-08): Compliance report uploaded for review.

07/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902000

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue:Insufficient asset documentation.

-

Allow retirement account to be documented by website printout vs. 2 months of statements. Per FNMA The account and its asset composition must be documented with the most recent monthly, quarterly, or annual statement. Does not meet FNMA requirements.

Credit history reflects paid as agreed since last installment and revolving lates in XXXXXX.  No public records. Borrower has been self employed for the past 17.48 years as a XXXXXX DTI is 30.807%, 19.193% < program maximum of 50%. Reserves are 29 months, 15 months > program requirement of 14 months (12 months plus one mortgage investment property). Credit score is 713, 13 points > program requirement of 700 LTV is 60%, 5% < program maximum of 65%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-10): Client has elected to waive this exception based on compensating factors. Reviewer Comment (2019-07-10): Cannot waive exception to FNMA guide. Requirement is for 2 month history, printout only shows most recent balance and is missing pages 3-5. Buyer Comment (2019-07-09): Please see approved exception

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

A

A

A

A

Non QM

Non QM

No

207902001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Missing evidence borrower was provided a copy of the Anti Steering Disclosure at time of application.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD reflects an amount of $75 that exceeds the legal limit yet increase in fees over the legal limit is $650.

Reviewer Comment (2019-07-10): Upon further review, the exception is cleared. Buyer Comment (2019-07-09): Please see INITIAL LE, Section H reflects $750 Survey was disclosed

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $650.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE did not reflect a Survey fee yet the final CD shows a fee of $650.

Reviewer Comment (2019-07-10): Upon further review, the exception is cleared. Buyer Comment (2019-07-09): Please see INITIAL LE, Section H reflects $750 Survey was disclosed

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902001

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided a copy of the LO Compensation Disclosure at time of application.

Buyer Comment (2019-07-08): XXXXXX has elected to waive this exception.

07/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902002

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-23): XXXXXX has elected to waive Reviewer Comment (2019-07-22): No LO compensating disclosure provided.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902002

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $155.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902002

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

The Borrower was not provided with list of service providers

Reviewer Comment (2019-07-22): AMC received the SSPL dated 5/XX19.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902002

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Broker

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXXX did not disclose the required  Broker  Contact Information (Broker Name, Broker NMLS ID, Contact Name, Contact NMLS ID).

Information not provided on Final Closing Disclosure.

Reviewer Comment (2019-07-24): Final CD provided with correct NMLS listed Reviewer Comment (2019-07-22): Broker listed on the final CD dated 6/XX19 however no Broker NMLS ID number was provided.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902002

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

The file contained documentation verifying the borrower was provided with a copy of the appraisal on XXXXXX, which is prior to the appraisal report date of XXXXXX. Evidence borrower received a copy of the revised appraisal was not provided.

Buyer Comment (2019-07-23): XXXXXX has elected to waive Reviewer Comment (2019-07-22): Appraisal received by Lender on 6/7/19 per D0054 however this date was prior to the report date of the appraisal of 6/XXXX.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902003

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The LE disclosed the Home Warranty Fee in Section H/Other; the final CD disclosed it in Section C.

Buyer Comment (2019-07-22): XXXXXX has elected to waive this exception.

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902003

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

The initial CD was provided on XXXX19 with no evidence of early receipt; the borrower signed on XXXX19.

Reviewer Comment (2019-07-23): AMC reviewed disclosure tracking indicating the XX21 CD was received XX22. Exception Cleared. Buyer Comment (2019-07-22): Initial CD provided

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902003

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Home Warranty.  Fee Amount of $500.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The LE disclosed the Home Warranty Fee in Section H/Other; the final CD disclosed it in Section C.

Reviewer Comment (2019-07-23): AMC received PCCD correcting fee placement and LOE. Exception Cured. Buyer Comment (2019-07-22): See PCCD & LOE provided

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902003

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Reviewer Comment (2019-07-10): Updated assets to satisfy reserves. Buyer Comment (2019-07-09): Additional busines asset statements provided for Reserves

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902004

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.04960% is in excess of allowable threshold of Prime Mortgage Market Rate 3.51000% + 1.75%, or 5.26000%.  Non-Compliant SubPrime Loan.

Loan is a Compliant NY Subprime Loan.  Exception downgraded to EV2-B.

Buyer Comment (2019-07-12): XXXXXX has elected to waive Reviewer Comment (2019-07-12): Loan is a Compliant NY Subprime Loan. EV2.

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902004

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/XXXX 12:00:00 AM was received.

Buyer Comment (2019-07-12): XXXXXX has elected to waive

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902004

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/XXXX 12:00:00 AM was received.

Buyer Comment (2019-07-12): XXXXXX has elected to waive

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902004

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower within three days of application.

Subprime Counseling disclosure dated XXXXXX.

Reviewer Comment (2019-07-12): Per LE's, loan changed from Fixed rate to ARM loan on XXXXXX.

07/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902004

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

The Final CD (XXXX19) did not disclose the Demand Feature.

Buyer Comment (2019-07-12): XXXXXX has elected to waive

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902004

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrowers company XXXXXX has been in existence since XXXX18 (14 months) vs program requirement that the borrower must have been continually self-employed for two years.

No public records Subject property is free and clear 133 months reserves > 3 months guideline minimum FICO is 733 > program requirement of 700 28.48% DTI < 50% guideline max 40.33% LTV < 85%guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-10): Client has elected to waive this exception based on compensating factors.

07/10/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902005

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

Missing Document: Credit Report not provided

Missing credit report.

Reviewer Comment (2019-07-10): Credit Report provided

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902005

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD does not reflect an amount by which the fees exceed the legal limit.

Reviewer Comment (2019-07-15): Tolerance exceptions are addressed. Exception Cleared. Buyer Comment (2019-07-12): uploaded pccd

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

207902005

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $800.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXX19 reflects an Appraisal fee of $800 yet the final CD shows a charge of $900.

Reviewer Comment (2019-07-15): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

207902005

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $30.00 exceeds tolerance of $5.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXX19 reflects a Title - Wire fee of $5 yet the final CD shows a fee of $30.

Reviewer Comment (2019-07-15): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-07-12): uploaded refund/pccd

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

207902005

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $800.00.  Sufficient or excess cure was provided to the borrower.

AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-07-15): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

07/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

207902005

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $30.00 exceeds tolerance of $5.00.  Sufficient or excess cure was provided to the borrower.

AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-07-15): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

07/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Final Title Policy not provided

Reviewer Comment (2019-08-15): Final Title Policy provided

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Disclosure not provided.  Loan Estimate is dated XXXX19; application was received on XXXX19.

Reviewer Comment (2019-07-15): AMC received required documents, exception is cleared.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.88890% or Final Disclosure APR of 8.41100% is in excess of allowable threshold of APOR 4.34% + 2.5%, or 6.84000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-08-01): Disclosure provided.

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-08-01): Disclosure provided. Buyer Comment (2019-08-01): Disclosure provided

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Timing

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Disclosure not provided.  Loan Estimate is dated XXXX19; application was received on XXXX19.

Reviewer Comment (2019-07-15): AMC received required documents, exception is cleared.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $22,813.25 and disclosure timing violations.

E-sign consent not provided.

Reviewer Comment (2019-07-15): E-consent provided. Buyer Comment (2019-07-12): Econsent provided

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AIR Table Minimum Interest Rate

TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Disclosure provided on XXXXXX disclosed a Minimum Interest Rate that does not match the actual minimum interest rate for the loan.

The AIR table on the final CD disclosed the start rate of 8.085% as the minimum rate; the Note disclosed the margin (3.25%) as the minimum rate.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-13): See revised executed Note showing correct minimum / floor rate. Reviewer Comment (2019-07-31): Letter of Explanation, Proof of Delivery, Corrected CD required to cure.  Post Close CD issued XXXXXX still reflects 8.085% as the minimum rate.  Per Note the minimum rate is the margin which is 3.25% Buyer Comment (2019-07-30): See PCCD provided

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

Due to the discrepancy in the disclosure of the minimum rate, the payment disclosed in payment stream 2 is inaccurate.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-13): See revised executed Note showing correct minimum / floor rate. Reviewer Comment (2019-07-31): Letter of Explanation, Proof of Delivery, Corrected CD required to cure.  Post Close CD issued XXXXXX still reflects 8.085% as the minimum rate.  Per Note the minimum rate is the margin which is 3.25% Buyer Comment (2019-07-30): See PCCD provided

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

Due to the discrepancy in the disclosure of the minimum rate, the payment disclosed in payment stream 3 is inaccurate.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-13): See revised executed Note showing correct minimum / floor rate. Reviewer Comment (2019-07-31): Letter of Explanation, Proof of Delivery, Corrected CD required to cure.  Post Close CD issued XXXXXX still reflects 8.085% as the minimum rate.  Per Note the minimum rate is the margin which is 3.25% Buyer Comment (2019-07-30): See PCCD provided

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

Due to the discrepancy in the disclosure of the minimum rate, the payment disclosed in payment stream 4 is inaccurate.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-13): See revised executed Note showing correct minimum / floor rate. Reviewer Comment (2019-07-31): Letter of Explanation, Proof of Delivery, Corrected CD required to cure.  Post Close CD issued XXXXXX still reflects 8.085% as the minimum rate.  Per Note the minimum rate is the margin which is 3.25% Buyer Comment (2019-07-30): See PCCD provided

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

Due to the discrepancy in the disclosure of the minimum rate, the Total Interest Percentage of 166.359 disclosed on the final is in accurate.  Calculated TIP is 122.406.

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit not provided to the borrower

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

The CD was provided at closing.

Reviewer Comment (2019-07-15): AMC received required documents, exception is cleared. Buyer Comment (2019-07-12): Initial CD provided

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

The LE was provided on XXXX19; the application was received on XXXX19.

Reviewer Comment (2019-07-15): AMC received required documents, exception is cleared. Buyer Comment (2019-07-12): See Initial LE provided

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Seven Day Waiting Period

TILA-RESPA Integrated Disclosure: Loan Estimate was not delivered or placed in the mail to the borrower at least seven (7) business days prior to closing.

The LE was provided on XXXX19; closing occurred on XXXX19.

Reviewer Comment (2019-07-15): AMC received required documents, exception is cleared. Buyer Comment (2019-07-12): See Initial LE provided

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Borrower not provided with List of Service Providers

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Reviewer Comment (2019-08-12): AMC received the signed ARM disclosure dated 6/XX19. Buyer Comment (2019-08-09): ARM Disclosure uploaded shows borrower acknowledged receipt as of 6/XXXX (ink signed by client) please clear. Reviewer Comment (2019-08-09): Change of Circumstance Disclosure (p164/D0241) dated XXXXXX shows the programs change from Fixed to ARM. However, the Method of deliver to applicant is blank and the form does not confirm the ARM Disclosure and CHARM booklet were included. Missing documentation of the date the Disclosure was provided to or received by the borrower. Buyer Comment (2019-08-08): ARM disclosure provided as of change of circumstance date 6.24.19

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Reviewer Comment (2019-08-01): CHARM booklet provided. Buyer Comment (2019-08-01): CHARM booklet uploaded prior page 22 denotes the date provided to the borrower as 6/XXXX matching the COC form dated 6/XXXX. Reviewer Comment (2019-07-31): Copy of CHARM Booklet in file. Missing documentation of the date the disclosure was provided to the borrower. The COC dated XXXXXX only indicates that the loan was locked. Buyer Comment (2019-07-30): CHARM provided 6/24 as of change of circumstance from Fixed to ARM program

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

Disclosure not provided.  The Loan Estimate was provided on XXXX19; the application was received on XXXX19.

Reviewer Comment (2019-07-15): AMC received required documents, exception is cleared.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $100.76 exceeds tolerance of $95.00.  Sufficient or excess cure was provided to the borrower at Closing.

Credit Report Fee Amount of $100.76 exceeds tolerance of $95.00 Sufficient cure was provided to the borrower at Closing

07/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XX exceeds tolerance of $XX.  Sufficient or excess cure was provided to the borrower at Closing.

Transfer Fee Amount of $20.00 exceeds tolerance of $15.00. Sufficient cure was provided to the borrower at Closing

07/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Title Error: Title vesting does not concur with deed

Title commitment disclosed vesting as borrower only; Security Instrument disclosed husband and wife.  Warranty deed not provided for verification.

Reviewer Comment (2019-08-15): Vesting on final title matches the mortgage and the recorded Deed. Buyer Comment (2019-08-14): See revised Title provided Reviewer Comment (2019-07-31): Warranty deed vesting in name of borrower and spouse. Title commitment shows shows the borrower only as a title holder. Mortgage was signed by the borrower and spouse. Provide a revised title report or supplement with vesting that matches the warranty deed. Buyer Comment (2019-07-30): Deed provided

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing verification of ownership % for XXXXXX

Reviewer Comment (2019-07-25): AMC received the filling information for both LLC's with business ownership percentage at 100% Reviewer Comment (2019-07-15): Business licence information already provided. Provide verification of ownership % for XXXXXX Buyer Comment (2019-07-12): Borrower is only party listed as Managing Member for both entities - see trailing documents - please clear

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

No changed circumstance was located in the loan file.  Unable to address the exception at this time.

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No changed circumstance was located in the loan file.  Unable to address the exception at this time.

Reviewer Comment (2019-08-09): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Buyer Comment (2019-08-08): PCCD and LOE provided Reviewer Comment (2019-07-31): AMC received Letter of Explanation, Proof of Delivery, Copy of Refund Check for $75, and Post Close CD issued XXXXXX.  The Post Close CD does not reflect the additional cure of $75 on page 1 as a lender credit, on page 2 in Section J as a cure and page 3 in the calculating cash to close section.  Please provided Corrected CD and LOE to borrower. Buyer Comment (2019-07-30): See PCCD cure documents provided

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $100.76 exceeds tolerance of $95.00.  Insufficient or no cure was provided to the borrower.

No changed circumstance was located in the loan file.  Unable to address the exception at this time.

Reviewer Comment (2019-07-26): AMC reviewed exception. A cure is indicated on the final CD. Exception Cured. Buyer Comment (2019-07-25): Final CD shows lender credit of $10.76 for closing cost over limit ($5.76 for CR Fee)

07/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XX exceeds tolerance of $XX.  Insufficient or no cure was provided to the borrower.

No changed circumstance was located in the loan file.  Unable to address the exception at this time.

Reviewer Comment (2019-07-26): AMC reviewed exception. A cure is indicated on the final CD. Exception Cured. Buyer Comment (2019-07-25): Final CD shows lender credit of $10.76 for closing cost over limit ($5.00 for TT)

07/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2019-08-12): Loan was disclosed as a Fixed rate at application X/X/XX and changed to an ARM on 6/XX19 per LE disclosure dated within 3 days of change 6/XX19. Buyer Comment (2019-08-09): See page 5 of trailing documents - CHARM provided electronically with COC as of 6.24.19. Please clear. Reviewer Comment (2019-08-09): Change of Circumstance Disclosure (p164/D0241) dated XXXXXX shows the programs change from Fixed to ARM. However, the Method of delivery to applicant is blank and the form does not confirm the ARM Disclosure and CHARM booklet were included. Missing documentation of the date the Disclosure was provided to or received by the borrower. Buyer Comment (2019-08-08): See trailing documents

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

Reviewer Comment (2019-08-09): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $100.76 exceeds tolerance of $95.00.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

Reviewer Comment (2019-08-09): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XX exceeds tolerance of $XX.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

Reviewer Comment (2019-08-09): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902006

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

Disclosure dated XXXX19 application date XXXX19.

Reviewer Comment (2019-08-12): Loan was disclosed as a Fixed rate at application X/X/XX and changed to an ARM on 6/XX19 per LE disclosure dated within 3 days of change 6/XX19.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Flood Certificate not provided

Reviewer Comment (2019-07-10): Flood Certificate provided

07/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.38010% or Final Disclosure APR of 6.41800% is in excess of allowable threshold of APOR 4.61% + 1.5%, or 6.11000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-18): Initial LE used for appraisal timing. Reviewer Comment (2019-07-15): Additional documentation will be required to support the fact the loan became XXXXXX  Subprime on 6/5 and not sooner.   Whereas AMC would typically look to the LE in file to determine the APR at the time the LE was issued, in this case the LE is missing from file.  The 1003 reflects the application was made as an ARM loan with an initial interest rate of 5.96%.  This is further supported by the rate lock in file dated 5/XX19 which also reflects an interest rate of 5.96%.  With a XXXXXX subprime threshold of 3.84% (PMMS) + 1.75% or 5.59%,  the loan appears to have been Subprime from the time of initial application.  Note that the grading on the timing exception is an EV2-B given that while the disclosure was not provided "at application", as specified in the Regulation, it was provided within three days of application, which AMC's outside counsel has agreed to an EV2-B citing.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.41660% is in excess of allowable threshold of Prime Mortgage Market Rate 3.84000% + 1.75%, or 5.59000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-30): XXXXXX has elected to waive Reviewer Comment (2019-07-18): Pending TRID review. Reviewer Comment (2019-07-15): Additional documentation will be required to support the fact the loan became XXXXXX  Subprime on 6/5 and not sooner.   Whereas AMC would typically look to the LE in file to determine the APR at the time the LE was issued, in this case the LE is missing from file.  The 1003 reflects the application was made as an ARM loan with an initial interest rate of 5.96%.  This is further supported by the rate lock in file dated 5/XX19 which also reflects an interest rate of 5.96%.  With a XXXXXX subprime threshold of 3.84% (PMMS) + 1.75% or 5.59%,  the loan appears to have been Subprime from the time of initial application.  Note that the grading on the timing exception is an EV2-B given that while the disclosure was not provided "at application", as specified in the Regulation, it was provided within three days of application, which AMC's outside counsel has agreed to an EV2-B citing.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Evidence borrower was provided the appraisal disclosure is missing from the loan file.

Reviewer Comment (2019-07-15): Right to receive a copy of the Appraisal Disclosure provided.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Evidence the borrower was provided the appraisal disclosure is missing from the loan file.

Reviewer Comment (2019-07-15): Right to receive a copy of the Appraisal Disclosure provided.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Evidence the borrower was provided the servicing disclosure is missing from the loan file.

Reviewer Comment (2019-07-18): Initial LE used for servicing discl. timing.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Evidence the borrower was provided the counseling disclosure is missing from the loan file.

Buyer Comment (2019-07-30): XXXXXX has elected to waive Reviewer Comment (2019-07-18): Pending TRID review. Reviewer Comment (2019-07-15): Additional documentation will be required to support the fact the loan became XXXXXX  Subprime on X/X and not sooner.   Whereas AMC would typically look to the LE in file to determine the APR at the time the LE was issued, in this case the LE is missing from file.  The 1003 reflects the application was made as an ARM loan with an initial interest rate of 5.96%.  This is further supported by the rate lock in file dated 5/XX19 which also reflects an interest rate of 5.96%.  With a XXXXXX subprime threshold of 3.84% (PMMS) + 1.75% or 5.59%,  the loan appears to have been Subprime from the time of initial application.  Note that the grading on the timing exception is an EV2-B given that while the disclosure was not provided "at application", as specified in the Regulation, it was provided within three days of application, which AMC's outside counsel has agreed to an EV2-B citing. Buyer Comment (2019-07-12): Turned into Subprime on 6-5

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Evidence the borrower received the CD at least 3 business days prior to closing not provided.

Reviewer Comment (2019-07-15): AMC received XX21 CD. Exception Cleared.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $13,234.12 may be required.

The LE is not provided in the loan file.

Reviewer Comment (2019-07-18): LE provided.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Evidence borrower received ARM disclosure not provided.

Reviewer Comment (2019-07-15): ARM Disclosure provided.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Evidence borrower received Charm disclosure not provided.

Reviewer Comment (2019-07-15): CHARM Disclosure provided.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

The final CD disclosed an Estimated Total Monthly Payment for payment stream 1 of $XXXX that does not match the actual total payment for the loan of $XXXX. Hazard collected on the CD in the amount of $XXX a month and per policy $XXX(annual premium $XXXX).

Reviewer Comment (2019-08-01): AMC received PCCD. Final CD escrow amount is consistent with IEADS. Exception Cleared. Reviewer Comment (2019-07-30): Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable required to cure. AMC using $1622 per year for HOI which is $135.17 per month while lender is using $130.42 per month for HOI which is $1565 per year.  HOI documents in file confirm premium of $1622.  If premium is $1565 please provide documents to confirm. Reviewer Comment (2019-07-19): Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable required to cure. AMC using $1622 per year for HOI which is $135.17 per month while lender is using $130.42 per month for HOI.  Unable to determine lenders figure.  Policy provided stated the $1622 has been paid in full. Buyer Comment (2019-07-18): Please see uploaded LE

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing the complianceEase or Mavent as required by Guides.

Reviewer Comment (2019-07-15): Mavent provided.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

Reviewer Comment (2019-07-26): ARM disclosure provided XXXXXX per Disclosure Summary Reviewer Comment (2019-07-18): ARM Disclosure is dated XXXXXX and initial app date is XXXXXX.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

.

Reviewer Comment (2019-07-18): Initial LE used for appraisal timing.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Timing

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

.

Reviewer Comment (2019-07-18): Initial LE used for appraisal timing.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $13,234.12 and disclosure timing violations.

AMC received XX21 CD that is e signed. Please provide E consent.

Reviewer Comment (2019-07-18): E-consent provided.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

AMC received XX21 CD. Please provide LEs and SSPL for review of tolerance exceptions.

Reviewer Comment (2019-07-30): COC and Revised LE provided - rate lock Reviewer Comment (2019-07-26): AMC received XX14 COC  however a corresponding LE is not located in file. Please provide corresponding LE. Reviewer Comment (2019-07-19): Change of circumstance required or cure required for increase in points from the LE to the CD. Buyer Comment (2019-07-18): Please see uploaded LE and SSPL

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Recording Service Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

AMC received XX21 CD. Please provide LEs and SSPL for review of tolerance exceptions.

Reviewer Comment (2019-07-18): LE provided. Buyer Comment (2019-07-18): Please see uploaded LE and SSPL

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $200.00 exceeds tolerance of $50.00.  Insufficient or no cure was provided to the borrower.

AMC received XX21 CD. Please provide LEs and SSPL for review of tolerance exceptions.

Reviewer Comment (2019-07-18): LE provided. Buyer Comment (2019-07-18): Please see uploaded LE and SSPL

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $5,637.50 exceeds tolerance of $4,100.00.  Insufficient or no cure was provided to the borrower.

.

Reviewer Comment (2019-07-30): COC and Revised LE provided - rate lock Reviewer Comment (2019-07-26): AMC received XX14 COC  however a corresponding LE is not located in file. Please provide corresponding LE. Reviewer Comment (2019-07-19): Change of circumstance required or cure required for increase in points from the LE to the CD.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Abstract / Title Search.  Fee Amount of $108.62 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

.

Reviewer Comment (2019-07-19): fees reconciled to Section B

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Tax Pick Up Fee.  Fee Amount of $250.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

..

Reviewer Comment (2019-07-19): fees reconciled to Section B

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902008

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Lender's Title Insurance.  Fee Amount of $985.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

.

Reviewer Comment (2019-07-19): fees reconciled to Section B

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-07-17): Appraisal Disclosure provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.54610% or Final Disclosure APR of 6.56300% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-17): Appraisal Disclosure provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-07-17): Appraisal Disclosure provided. Buyer Comment (2019-07-16): Appraisal disclosure provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

The Disclosure was provided at closing.

Reviewer Comment (2019-07-17): Appraisal Disclosure provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-07-17): XXXXXX has elected to waive this exception.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The final CD disclosed that the loan is not assumable; the Note disclosed that the loan is assumable.

Buyer Comment (2019-07-17): XXXXXX has elected to waive this exception.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $6,820.50 may be required.

The Loan Estimate was not provided.

Reviewer Comment (2019-07-17): AMC received LEs. Exception Cleared. Buyer Comment (2019-07-16): LE's and COC's provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Courier / Express Mail / Messenger Fee.  Fee Amount of $40.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Title - Courier Fee was added to the final CD without a valid change of circumstance.

Reviewer Comment (2019-07-17): AMC received LEs. Exception Cleared. Buyer Comment (2019-07-16): LE and COC's provided Reviewer Comment (2019-07-16): AMC received SSPL. Please provide LEs to review tolerance exceptions. Buyer Comment (2019-07-15): SSPL provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Processing Fee.  Fee Amount of $35.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Title - Erecording Processing Fee was added to the final CD without a valid change of circumstances.

Reviewer Comment (2019-07-17): AMC received LEs. Exception Cleared. Buyer Comment (2019-07-16): LE and COC's provided Reviewer Comment (2019-07-16): AMC received SSPL. Please provide LEs to review tolerance exceptions. Buyer Comment (2019-07-15): SSPL provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Tax Pick Up Fee.  Fee Amount of $95.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Title - Stamp Pick up Fee was added to the final CD without a valid change of circumstances.

Reviewer Comment (2019-07-17): AMC received LEs. Exception Cleared. Buyer Comment (2019-07-16): LE and COC's provided Reviewer Comment (2019-07-16): AMC received SSPL. Please provide LEs to review tolerance exceptions. Buyer Comment (2019-07-15): SSPL

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $540.00 exceeds tolerance of $360.00.  Insufficient or no cure was provided to the borrower.

The final CD increased the Title - Endorsement Fees without a valid change of circumstance.

Reviewer Comment (2019-07-17): AMC received LEs. Exception Cleared. Buyer Comment (2019-07-16): LE and COC's provided Reviewer Comment (2019-07-16): AMC received SSPL. Please provide LEs to review tolerance exceptions. Buyer Comment (2019-07-15): SSPL provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Prior to Closing Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower at least three (3) days prior to consummation for a loan that did not start as an ARM.

The disclosure was provided at closing.

Reviewer Comment (2019-07-17): Initial ARM discl provided. Buyer Comment (2019-07-17): ARM disclosure and E doc tracking provided showing delivery as of 6/24. Please clear. Reviewer Comment (2019-07-17): Per LE, program changed to an ARM on XXXXXX. The ARM disclosure has no provided date, but was signed on XXXX21019. Not within 3 days of consummation. Buyer Comment (2019-07-16): ARM disclosure provided with applicable COC

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

The file did not contain evidence that the toolkit was provided to the borrower.

Reviewer Comment (2019-07-17): Home Loan Toolkit Provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Reviewer Comment (2019-07-17): Disclosure  Provided Reviewer Comment (2019-07-17): Booklet disclosure only reflects Home Loan Toolkit provided, not CHARM booklet. Reviewer Comment (2019-07-17): CHARM Booklet not provided in trailing docs. Buyer Comment (2019-07-16): CHARM booklet disclosure provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD did not provide a tolerance cure of $350.00 for the increase to the title fees.

Buyer Comment (2019-07-17): XXXXXX has elected to waive this exception.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Divorce Decree / Child Support not provided

Lender approved exception to allow Attorney letter confirming both parties are in the process of filing for a Petition of Dissolution vs program requirement of providing a Legal Separation Agreement or Divorce Decree.

Perfect mortgage history with 1 active mortgage paid as agreed since inception XXXXXX.  No public records. DTI is 26.44% < program maximum of 50% Reserves are 110 of the loan amount ($420,750) plus 10.88 months PITI reserves ($41,381.50), 7.88 months > program requirement of 110% of loan amount plus 3 months ($11,131.50). Credit score is 789, 109 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-11): Client has elected to waive this exception based on compensating factors.

07/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing compliance report. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-07-17): Compliance report provided Buyer Comment (2019-07-16): Compliance report provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Appraisal Disclosure not provided within 3 days of application date.

Reviewer Comment (2019-07-17): Appraisal Disclosure provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Timing

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Appraisal Disclosure not provided within 3 days of application date.

Reviewer Comment (2019-07-17): Appraisal Disclosure provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Provided Through Home Loan Toolkit

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet provided to the borrower through Home Loan Toolkit.

Buyer Comment (2019-07-17): XXXXXX has elected to waive this exception.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

AMC received XX17 LE received XX20 however the earliest E consent is dated XX12. Please provide earliest E consent available.

Reviewer Comment (2019-07-22): Trailing doc accepted reflecting initial e-consent was provided on 5/XX19. Exception cleared. Reviewer Comment (2019-07-18): The DocuSign disclosure that's dated 5/17 is not the e-Consent we're looking for, but rather the e-tracking document for e-delivery and e-receipt of the initial package sent to the consumer which included the initial LE and other miscellaneous application package disclosed. Prior to this delivery, there should be an acceptance by the consumer to receive these disclosures by email. In order to clear the timing exception for the LE being delivered prior to e-Consent, we would need to see when the consumer consented to receiving the disclosures electronically. Buyer Comment (2019-07-18): See trailing documents

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on XXXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.

AMC received XX17 LE received XX20 however the earliest E consent is dated XX12. Please provide earliest E consent available.

Reviewer Comment (2019-07-22): Trailing doc accepted reflecting e-consent was received on 5/XX19. Exception cleared. Reviewer Comment (2019-07-18): The DocuSign disclosure that's dated 5/17 is not the e-Consent we're looking for, but rather the e-tracking document for e-delivery and e-receipt of the initial package sent to the consumer which included the initial LE and other miscellaneous application package disclosed. Prior to this delivery, there should be an acceptance by the consumer to receive these disclosures by email. In order to clear the timing exception for the LE being delivered prior to e-Consent, we would need to see when the consumer consented to receiving the disclosures electronically. Buyer Comment (2019-07-18): Econsent provided

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on XXXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.

AMC received XX24 LE received XX24 however the earliest E consent is dated XX12. Please provide earliest E consent available.

Reviewer Comment (2019-07-22): Trailing doc accepted reflecting e-consent was received on 5/XX19. Exception cleared. Reviewer Comment (2019-07-18): The DocuSign disclosure that's dated 5/17 is not the e-Consent we're looking for, but rather the e-tracking document for e-delivery and e-receipt of the initial package sent to the consumer which included the initial LE and other miscellaneous application package disclosed. Prior to this delivery, there should be an acceptance by the consumer to receive these disclosures by email. In order to clear the timing exception for the LE being delivered prior to e-Consent, we would need to see when the consumer consented to receiving the disclosures electronically. Buyer Comment (2019-07-18): See trailing documents

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/XXXX 12:00:00 AM was received.

AMC received XX24 LE without indication of receipt therefore XX27 is receipt due to mailbox rule. Please provide earlier receipt if available.

Buyer Comment (2019-07-18): XXXXXX has elected to waive this exception.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902009

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXXX not received by borrower at least four (4) business days prior to closing.

AMC received XX24 LE without indication of receipt therefore XX27 is receipt due to mailbox rule. Please provide earlier receipt if available.

Reviewer Comment (2019-07-23): AMC received the the LE dated 6/XXXX electronically signed and received on 6/XX19. Reviewer Comment (2019-07-18): The DocuSign disclosure that's dated 5/17 is not the e-Consent we're looking for, but rather the e-tracking document for e-delivery and e-receipt of the initial package sent to the consumer which included the initial LE and other miscellaneous application package disclosed. Prior to this delivery, there should be an acceptance by the consumer to receive these disclosures by email. In order to clear the timing exception for the LE being delivered prior to e-Consent, we would need to see when the consumer consented to receiving the disclosures electronically. Buyer Comment (2019-07-18): LE esigned 6.24.19 provided

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.83090% or Final Disclosure APR of 6.58900% is in excess of allowable threshold of APOR 4.58% + 1.5%, or 6.08000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-23): See newly added exception.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Appraisal Disclosure provided XXXX19 vs application date of XXXX19.

Reviewer Comment (2019-07-23): Initial LE provided dated 5/XX19.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Timing

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Appraisal Disclosure provided XXXX19 vs application date of XXXX19.

Reviewer Comment (2019-07-23): Initial LE provided dated 5/XX19.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Amount Financed

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed an Amount Financed that was not within tolerance of the actual amount financed for the loan.

Finance charges under disclosed by -$410.00 missing the compliance report unable to determine fees causing the under disclosure.

Reviewer Comment (2019-08-15): Letter of Explanation, Proof of Delivery, Corrected CD and Rescission re-opened and expired Buyer Comment (2019-08-14): Rescission has ended Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission which expires at midnight on X/X/XX.  Exception can be cured after rescission ends. Reviewer Comment (2019-07-23): PCCD dated 7/XX19 received. Need rescission reopened, letter of explanation provided to Borrower and POD to cure.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

The CD was provided at closing.

Reviewer Comment (2019-07-23): Initial CD dated 5/XX19 was provided.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

LE was provided on XXXX19, application was received on XXXX19.

Reviewer Comment (2019-07-23): Initial LE provided.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AIR Table Minimum Interest Rate

TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Disclosure provided on XXXXXX disclosed a Minimum Interest Rate that does not match the actual minimum interest rate for the loan.

The Final CD disclosed a minimum Interest rate of of 3.25% (margin); the Note disclosed the start rate of 6.335% as the minimum rate.

Reviewer Comment (2019-08-15): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-08-14): Rescission has ended Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission which expires at midnight on X/X/XX.  Exception can be cured after rescission ends. Buyer Comment (2019-08-02): Please see uploaded documents Reviewer Comment (2019-07-23): PCCD dated 7/XX19 received. Need letter of explanation provided to Borrower to cure.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

The payment for payment stream 2 is inaccurate due to the discrepancy in the minimum rate.

Reviewer Comment (2019-08-15): Letter of Explanation, Proof of Delivery, Corrected CD, and Rescission re-opened and expired 8/5/XX Buyer Comment (2019-08-14): Rescission has ended Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission which expires at midnight on X/X/XX.  Exception can be cured after rescission ends. Buyer Comment (2019-08-02): Please see uploaded documents Reviewer Comment (2019-07-23): PCCD dated 7/XX19 received. Need rescission reopened, letter of explanation provided to Borrower and POD to cure.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

The payment for payment stream 3 is inaccurate due to the discrepancy in the minimum rate.

Reviewer Comment (2019-08-15): Letter of Explanation, Proof of Delivery, Corrected CD, and Rescission re-opened and expired 8/5/XX Buyer Comment (2019-08-14): Rescission has ended Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission which expires at midnight on X/X/XX.  Exception can be cured after rescission ends. Buyer Comment (2019-08-02): Please see uploaded documents Reviewer Comment (2019-07-23): PCCD dated 7/XX19 received. Need rescission reopened, letter of explanation provided to Borrower and POD to cure.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

The payment for payment stream 4 is inaccurate due to the discrepancy in the minimum rate.

Reviewer Comment (2019-08-15): Letter of Explanation, Proof of Delivery, Corrected CD, and Rescission re-opened and expired 8/5/XX Buyer Comment (2019-08-14): Rescission has ended Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission which expires at midnight on X/X/XX.  Exception can be cured after rescission ends. Buyer Comment (2019-08-02): Please see uploaded documents Reviewer Comment (2019-07-23): PCCD dated 7/XX19 received. Need rescission reopened, letter of explanation provided to Borrower and POD to cure.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

The Total Interest Percentage of 115.802% disclosed on the CD does not match the calculated TIP of 123.722%.

Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation and Corrected CD, Buyer Comment (2019-08-02): Please see uploaded documents Reviewer Comment (2019-07-23): PCCD dated 7/XX19 received. Need letter of explanation provided to Borrower to cure.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total of Payments that does not match the actual total of payments for the loan.

The total of payments is incorrect as Index used is below the minimum available index of  2.16150% in the lookback.

Reviewer Comment (2019-08-07): Rescission has expired. Exception Cured. Buyer Comment (2019-08-06): Rescission expired Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission which expires at midnight on X/X/XX.  Exception can be cured after rescission ends. Buyer Comment (2019-08-02): Please see uploaded documents Reviewer Comment (2019-07-23): PCCD dated 7/XX19 received. Need rescission reopened, letter of explanation provided to Borrower and POD to cure.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

The Finance Charge of  $151,422.18 on CD does not match the calculated finance charge of $160,912.09.

Reviewer Comment (2019-08-29): AMC received an attestation for the 2 CDs issued on 6/XX19 to clarify which one was the final at closing. Reviewer Comment (2019-08-29): AMC received another final CD issued on 6/XX19 and wet signed on 6/XX19 with different finance charge on page 5 of $161,322.09.  This is an increase from the other final CD issued on same date and also wet signed by the Borrower on 6/XX19.  Unable to determine which one is the actual final CD used at the closing.  Please provide an attestation as to the 2 final CD's.  In addition, the under-disclosed amount will depend on which one is the actual CD and a refund will be required. Buyer Comment (2019-08-28): there were 2 CDs drawn up at the time of docs and Escrow only sent one to the our office. Also, we have a revised CD that was marked inactive in our system. Could you please review and see if this would clear the file? Reviewer Comment (2019-08-15): Final Closing Disclosure provided on XXXXXX disclosed an Amount Financed that was not within tolerance of the actual amount financed for the loan - The Note states the rate will never be less than 6.335% and the Final CD at closing on page 4 reflected 3.25%.  As a result there is a Finance Charge under disclosure of $9,489.91 and a cure check and proof of delivery is required. Buyer Comment (2019-08-14): Rescission has ended Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission which expires at midnight on 8/5/19.  Exception can be cured after rescission ends. Buyer Comment (2019-08-02): Please see uploaded documents Reviewer Comment (2019-07-23): PCCD dated 7/XX19 received. Need rescission reopened, letter of explanation provided to Borrower and POD to cure.

08/29/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: 1003 Final is incomplete

Final 1003 not provided for co-borrower.  Initial 1003s had borrower and co-borrower on separate forms.  Co-borrower signed Borrower's final 1003 but co-borrower's information was not disclosed in the document.

Reviewer Comment (2019-08-07): Final signed 1003 provided for the co-borrower

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

-

Per notes on 1008, charge off to be paid off at closing.  Payoff not disclosed on CD.

Reviewer Comment (2019-08-15): AMC received credit supplement dated 8/XX19 with account reflecting paid in full on 6/XX19.

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Post Close Closing Disclosure Timing Irregular Transactions

TILA-RESPA Integrated Disclosure - Three-Day Waiting Period Timing Violation.  Post Closing Disclosure reflects a change in APR, loan product, or addition of prepayment penalty which would have triggered an additional 3-day waiting period had it been correctly disclosed on the Final Closing Disclosure.

PCCD dated XXXX19 disclosed an APR of 6.872% which is an increase of .283% from final CD of 6.589%.

Reviewer Comment (2019-08-29): A revised CD issued on 6/XX19 was provided. Buyer Comment (2019-08-28): there were 2 CDs drawn up at the time of docs and Escrow only sent one to the our office. Also, we have a revised CD that was marked inactive in our system. Could you please review and see if this would clear the file? Reviewer Comment (2019-08-15): Exception is not curable as it is a timing issue.  The Post Close CD increased the minimum floor rate from 3.25% to 6.335% thus increasing  the APR above the threshold. Buyer Comment (2019-08-14): Rescission has ended Reviewer Comment (2019-08-02): AMC is in receipt of the following; Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission which expires at midnight on 8/5/19.  Exception can be cured after rescission ends. Buyer Comment (2019-08-02): Please see uploaded documents

08/29/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 5/XXXX 12:00:00 AM was received.

Revised LE dated XXXX19 with initial CD dated XXXX19.  Need evidence of earlier receipt of revised LE to clear.

Reviewer Comment (2019-07-23): Revised LE signed on 5/XX19

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AIR Table Minimum Interest Rate

TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Disclosure provided on XXXXXX disclosed a Minimum Interest Rate that does not match the actual minimum interest rate for the loan.

PCCD, LOE, RTC and POD has been received.

Reviewer Comment (2019-08-29): Letter of Explanation & Corrected Closing Disclosure provied.

08/29/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

PCCD, LOE, RTC and POD has been received.

Reviewer Comment (2019-08-29): Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission provided.

08/29/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

PCCD, LOE, RTC and POD has been received.

Reviewer Comment (2019-08-29): Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission provided.

08/29/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902010

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed a periodic principal and interest payment for payment stream 2 that does not match the actual payment for the loan.

PCCD, LOE, RTC and POD has been received.

Reviewer Comment (2019-08-29): Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission provided.

08/29/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.50160% or Final Disclosure APR of 6.51200% is in excess of allowable threshold of APOR 4.56% + 1.5%, or 6.06000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-17): Loan is Compliant Higher Priced Loan

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Reviewer Comment (2019-07-16): Disclosure provided.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-07-16): Disclosure provided.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-07-16): Disclosure provided. Buyer Comment (2019-07-16): Disclosure tracking provided Buyer Comment (2019-07-16): Appraisal disclosure provided

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

The Disclosure or the Loan Estimate were not provided.

Reviewer Comment (2019-07-16): Disclosure provided.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902011

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower.

Reviewer Comment (2019-07-16): Disclosure provided.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.50160% is in excess of allowable threshold of Prime Mortgage Market Rate 3.66000% + 1.75%, or 5.41000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-07-17): Disclosure provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Evidence that the borrower received the toolkit was not provided.

Reviewer Comment (2019-07-16): Disclosure provided.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $16,665.15 may be required.

LE not provided.

Reviewer Comment (2019-07-17): LE's provided Buyer Comment (2019-07-16): Econsent included Buyer Comment (2019-07-16): SSPL also provided Buyer Comment (2019-07-16): LE's provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Reviewer Comment (2019-07-16): Disclosure provided. Buyer Comment (2019-07-16): ARM disclosure provided

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Reviewer Comment (2019-07-16): Disclosure provided. Buyer Comment (2019-07-16): CHARM booklet provided / Disclosure Tracking also included.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate Adjusts Every

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on XXXXXX with an increasing interest rate disclosed a frequency adjustment that does not match the actual adjustment period for the loan.

The final CD disclosed the first interest rate change in month 60 however projected payment first change occurs in month 61 (year 6)

Reviewer Comment (2019-07-19): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-07-18): See PCCD and LOE provided

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Interest Rate Adjusts Starting In

TILA-RESPA Integrated Disclosure - Loan Terms: Final Closing Disclosure provided on XXXXXX with an increasing interest rate disclosed a frequency adjustment that does not match the actual adjustment period for the loan.

The final CD disclosed the first interest rate change in 60 months; calculated rate change is 6 years.

Reviewer Comment (2019-07-19): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-07-18): See trailing documents

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

The CD was provided at closing.

Reviewer Comment (2019-07-17): Initial CD provided Buyer Comment (2019-07-16): Initial CD provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Notice of Taxes and Insurance Not Provided)

XXXXXX Subprime Loan: Borrower not provided with Notice of Taxes and Insurance on 1st lien, subprime loan.

Reviewer Comment (2019-07-16): Disclosure provided. Buyer Comment (2019-07-16): LE provided.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Borrower does not have the minimum active tradelines per guidelines.

Approved exception.  Borrower has one open active tradeline longer than 12 months (no recent closed accounts, no VOR, lives rent-free) vs program requirement of 3 tradelines of which two must be active with 12 month history.

No public records. Borrower has been self employed for the past 10 years as XXXXXX Reserves are 25 months ($87,972), 22 months > program requirement of 3 months. Guideline variance approved by lender at time of origination.  DTI is 44.91%, 5.09% < program maximum of 50%. Credit score is 704, 4 points > program requirement of 700. LTV is 80%, 10% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-12): Client has elected to waive this exception based on compensating factors.

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Divorce Decree / Child Support not provided

Approved exception.  Use of child support income of $2,400/month with only 2 months documented evidence of receipt (XXXX and XXXX).  Previous amount was $27XXweek and bank statements in file for > 6 months support receipt.  Amount was increased to $2400/month per March XX marital settlement documents from attorney.

No public records. Borrower has been self employed for the past 10 years as XXXXXX Reserves are 25 months ($87,972), 22 months > program requirement of 3 months. Guideline variance approved by lender at time of origination.  DTI is 44.91%, 5.09% < program maximum of 50%. Credit score is 704, 4 points > program requirement of 700. LTV is 80%, 10% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-12): Client has elected to waive this exception based on compensating factors.

07/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing the ComplianceEase or Mavent as required per the guides.

Reviewer Comment (2019-07-17): Compliance Report provided Buyer Comment (2019-07-16): Compliance Report provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Compliant)

XXXXXX Subprime Loan: Counseling Disclosure not compliant.

Reviewer Comment (2019-07-17): Disclosure provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

.

Reviewer Comment (2019-07-17): Initial LE provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Timing

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

.

Reviewer Comment (2019-07-17): Initial LE provided. Buyer Comment (2019-07-17): Disclosure provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.50160% is in excess of allowable threshold of Prime Mortgage Market Rate 3.66000% + 1.75%, or 5.41000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-18): XXXXXX has elected to waive this exception.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

File missing change of circumstance for extension fee.

Buyer Comment (2019-07-18): XXXXXX has elected to waive this exception.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902011

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Extension Fee.  Fee Amount of $1,280.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

File missing change of circumstance for extension fee.

Reviewer Comment (2019-07-19): Revised CD and COC provided - rate lock extension Buyer Comment (2019-07-18): See COC provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.09110% or Final Disclosure APR of 7.09400% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE application dated 4/XX19 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Exception remains due to remaining open exceptions.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.09110% is in excess of allowable threshold of Prime Mortgage Market Rate 3.51000% + 1.75%, or 5.26000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE application dated 4/XX19 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Exception remains due to remaining open exceptions.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

Initial application date is XXXX19 yet earliest LE issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE application dated 4/XX19 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

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

Initial application date is XXXX19 yet earliest disclosure issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE of application dated 4/XX19 was for another previous loan application with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application. Buyer Comment (2019-07-24): Please see uploaded attestation letter

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

Initial application date is XXXX19 yet earliest disclosure issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE of application dated 4/XX19 was for another previous loan application with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application. Buyer Comment (2019-07-24): Please see uploaded attestation letter

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Initial application date is XXXX19 yet earliest disclosure issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE of application dated 4/XX19 was for another a previous loan application with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application. Buyer Comment (2019-07-24): Please see uploaded attestation letter

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Initial application date is XXXX19 yet earliest disclosure issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE application dated 4/XX19 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application. Buyer Comment (2019-07-24): Please see uploaded attestation letter

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Timing

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Initial application date is XXXX19 yet earliest disclosure issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE application dated 4.22.19 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application. Buyer Comment (2019-07-24): Please see uploaded attestation letter

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

Initial application date is XXXX19 yet earliest disclosure issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE application dated 4/XX19 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application. Buyer Comment (2019-07-24): Please see uploaded attestation letter

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Initial application date is XXXX19 yet earliest disclosure issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxxand LOE application dated 4/XX19 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application. Buyer Comment (2019-07-24): Please see uploaded attestation letter

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

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

Initial application date is XXXX19 yet earliest disclosure issued to the borrower on XXXX19.

Reviewer Comment (2019-07-25): Received initial application dated xxxx and LOE application dated 4/XX19 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003 Reviewer Comment (2019-07-25): Lender has provided a processor certification as to the application dated XXXXXX. Based on this certification, file is missing the initial loan application. Buyer Comment (2019-07-24): Please see uploaded attestation letter

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower.

Missing documentation.

Reviewer Comment (2019-07-25): Counseling Disclosure provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage)

XXXXXX Subprime Loan:  Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law.

Missing documentation.

Reviewer Comment (2019-07-25): Copy of revised mortgage with subprime language provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Provide the following:  Letter of Explanation,  corrected Mortgage (with required Legend), and proof of mailing.  Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery.  Best Practice would be to have signed and re-recorded Mortgage.).

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902012

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower within three days of application.

Missing copy of initial loan application.

Reviewer Comment (2019-07-25): Received initial application dated xxx and LOE application dated 4/22 was for another previous loan with borrower. Buyer Comment (2019-07-25): Please see uploaded 1003

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.09110% is in excess of allowable threshold of Prime Mortgage Market Rate 3.51000% + 1.75%, or 5.26000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-25): XXXXXX has elected to waive

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902012

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Disclosure provided on XXXX19 application date XXXX19.

Buyer Comment (2019-07-25): XXXXXX has elected to waive

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902013

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - S-Corp Test

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status using reasonably reliable third-party records.

Missing current reliable third party verification of borrower's business.

Reviewer Comment (2019-07-15): Business lic information provided.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902013

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Missing current reliable third party verification of borrower's business.

Reviewer Comment (2019-07-15): Business lic information provided. Buyer Comment (2019-07-15): uploaded LLC Status

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902013

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Missing current reliable third party verification of borrower's business.

Reviewer Comment (2019-07-15): Business lic information provided.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902013

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $670.00 exceeds tolerance of $650.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXX19 reflects an Appraisal fee of $650 yet the final CD shows a charge of $670.

Reviewer Comment (2019-07-22): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902013

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XX26XX19 does not reflect a Title - Endorsement fee yet the final CD shows a charge of $25.

Reviewer Comment (2019-07-22): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902013

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The CD (XXXX19) did not disclose and amount by which the Total Closing Cost exceed the legal limit.

Reviewer Comment (2019-07-22): Letter of Explanation & Corrected Closing Disclosure provided

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902013

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Verification of Non-US Citizen Status not provided

Initial 1003 and Final 1003 does not reflect the borrower as a U.S. Citizen or Permanent Resident Alien.  Missing proof of Non US Citizenship Status.

Reviewer Comment (2019-07-15): Corrected 1003 provided. Borrower is a US citizen. Buyer Comment (2019-07-15): The borrower is a US Citizen. corrected 1003 uploaded. driver license and SS card are located in file

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902013

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $670.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

Reviewer Comment (2019-07-22): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902013

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

Reviewer Comment (2019-07-22): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided an incorrect amount that the Total Closing Costs exceeded the legal limit

Reviewer Comment (2019-07-16): AMC received information that mortgage tax fee and transfer tax were a lump sum on the LE.  Mortgage tax increased with loan amount. Reviewer Comment (2019-07-16): AMC received COC for loan amount increase.  PurXXXXXX transaction transfer taxes based on purXXXXXX price of the property. PurXXXXXX price remained at $xxxx from Initial LE to Final CD.  Exception remains cure due to borrower.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902014

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXXX exceeds tolerance of $9,502.00.  Insufficient or no cure was provided to the borrower.

Transfer Tax fee  amount of xxxx exceeds tolerance of $9,502.00. No cure was provided to the borrower

Reviewer Comment (2019-07-16): AMC received information that mortgage tax fee and transfer tax were a lump sum on the LE.  Mortgage tax increased with loan amount. Reviewer Comment (2019-07-16): AMC received COC for loan amount increase.  PurXXXXXX transaction transfer taxes based on purXXXXXX price of the property. PurXXXXXX price remained at $xxxx from Initial LE to Final CD.  Exception remains cure due to borrower.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902014

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing VOE for borrower's employment with XXXXXX

Reviewer Comment (2019-07-15): VOE provided.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-07-30): AMC received the approval dated 7/XX19. Buyer Comment (2019-07-30): Approval uploaded for review.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing CDA or ARR

Reviewer Comment (2019-07-17): CDA provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-26): Appraisal provided on XXXXXX

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account Statement Missing

RESPA: Initial escrow account statement was not provided to the borrower.

Buyer Comment (2019-08-05): waive Reviewer Comment (2019-08-05): Initial escrow account statement was not provided in trailing docs. Reviewer Comment (2019-07-17): Initial escrow account statement was not provided in trailing docs.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Reviewer Comment (2019-07-26): List of Homeowner Counseling Org provided Reviewer Comment (2019-07-17): Homeownership Counseling List not provided in trailing docs.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Reviewer Comment (2019-07-17): Disclosure summary provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Reviewer Comment (2019-07-17): Disclosure summary provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Right to receive a copy of the Appraisal is missing from file

Reviewer Comment (2019-07-22): AMC received initial LE. Exception Cleared.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

SSPL is missing from file

Reviewer Comment (2019-07-22): AMC received initial LE. Exception Cleared.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure AIR Table Index And Margin

TILA-RESPA Integrated Disclosure - Adjustable Interest Rate Table: Final Closing Disclosure provided on XXXXXX did not disclose Index or Margin.

AIR table is incomplete on the Final CD. Does not indicate which Index is used.

Reviewer Comment (2019-07-30): LOE and corrected PCCD sent to borrower with completed AIR table. Reviewer Comment (2019-07-22): AMC received PCCD however the AIR table was not corrected. Please provide PCCD and LOE to cure.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

XXXXXX is Dry Funding state.  Closing date does not match date of consummation.

Buyer Comment (2019-08-05): waive Reviewer Comment (2019-08-05): Letter of Explanation & Corrected Closing Disclosure required to cure.  Closing occurred on XXXXXX Post Close CD reflects XXXXXX

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Not Have Escrow -  Reason

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan will have an escrow account.

Investor guidelines require Taxes and Insurance be escrowed.  Final CD in file does not reflect escrows.

Reviewer Comment (2019-08-05): Letter of Explanation & Corrected Closing Disclosure provided Reviewer Comment (2019-07-22): AMC received PCCD correcting escrow section. Please provide LOE to cure.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit not located in file.

Reviewer Comment (2019-07-17): Disclosure summary provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Final CD issued XXXX19. Date of Closing XXXX19.  Date of Consummation XXXX19.  Final CD not provided three business day prior to closing. Note: CA is dry funding state, date of closing is not necessarily date of disbursement.

Reviewer Comment (2019-07-22): AMC received the initial CD. Exception Cleared.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $7,805.50 may be required.

Loan Estimate missing from file. Tolerance testing based upon Final CD.

Reviewer Comment (2019-07-22): AMC received initial LE. Exception Cleared.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller's final CD missing from file.

Reviewer Comment (2019-07-19): AMC received the Seller CD dated 6/XX19.

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Engine Required. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-07-19): AMC received the Mavent compliance report dated 7/XX19 with an Alert/Pass review status.

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Compliant Test

TIL variable rate disclosure: ARM loan program disclosure does not match terms of loan.

Reviewer Comment (2019-07-22): ARM Disclosure to be provided for review

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

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

.

Reviewer Comment (2019-07-22): SSPL to be provided for review.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $7,805.50 and disclosure timing violations.

AMC received LE and initial that are e signed. Please provide E Consent.

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

AMC received LE and initial that are e signed. Please provide E Consent.

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): Please see uploaded E-Cosent

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Please provide SSPL for review.

Reviewer Comment (2019-07-26): Settlement Service Providers list provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

AMC received XX07 LE however application date is XX07. Please provide all LEs for review.

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

AMC received XX07 LE however application date is XX07. Please provide all LEs for review.

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

Yes

207902015

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/XXXX 12:00:00 AM was received.

XX7 LE was esigned on XX7, and XX6 LE was subject to mailbox rule and was not received until after the XXXXXX LE.

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.92220% or Final Disclosure APR of 7.96900% is in excess of allowable threshold of APOR 4.34% + 1.5%, or 5.84000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-19): Appraisal emailed XXXXXX Buyer Comment (2019-07-19): See trailing documents

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $7,851.06 may be required.

Missing evidence borrower was provided the Loan Estimate within 3 days of initial application.

Reviewer Comment (2019-07-22): AMC received required documents, exception is cleared. Buyer Comment (2019-07-19): SSPL and Econsent provided Buyer Comment (2019-07-19): LE's provided

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Missing evidence borrower was provided the disclosure within 3 days of initial application.

Reviewer Comment (2019-07-19): ARM disclosure provided on XXXXXX Buyer Comment (2019-07-19): ARM disclosure provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Missing evidence borrower was provided the disclosure within 3 days of initial application.

Reviewer Comment (2019-07-19): CHARM booklet provided on XXXXXX Buyer Comment (2019-07-19): CHARM disclosure provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence borrower was provided the disclosure within 3 days of initial application.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing evidence borrower was provided the disclosure within 3 days of initial application.

Reviewer Comment (2019-07-19): Right to receive appraisal dated XXXXXX Buyer Comment (2019-07-19): Provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing evidence borrower was provided the disclosure within 3 days of initial application.

Reviewer Comment (2019-07-19): Right to received appraisal dated XXXXXX Buyer Comment (2019-07-19): Appraisal disclosure provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Missing evidence borrower was provided a copy of the appraisal a minimum of 3 days prior to closing.

Reviewer Comment (2019-07-19): Documentation of appraisal email to borrower on XXXXXX Buyer Comment (2019-07-19): Evidence provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Missing evidence borrower was provided a copy of the appraisal a minimum of 3 days prior to closing.

Reviewer Comment (2019-07-19): Documentation of appraisal email to borrower on XXXXXX Buyer Comment (2019-07-19): Delivery Confirmation of Appraisal report provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

Servicing Disclosure within 3 days of the loan application date.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Note reflects assumption is permitted yet the final CD on page 4 indicates assumption is not allowed.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902016

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing July XX bank statement for $5,879.68 August $20,533.90 and June XX $5,879.29 used by Lender to qualify borrower's income $884.29 a month. This was in additional  to income of $2,691.45 a month used by the Lender.

Reviewer Comment (2019-07-17): Updated bank statement income. Buyer Comment (2019-07-16): Missing Bank statements utilized for income calc provided.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Missing July XX bank statement for $5,879.68 August $20,533.90 and June XX $5,879.29 used by Lender to qualify borrower's income $884.29 a month. This was in additional  to income of $2,691.45 a month used by the Lender.

Reviewer Comment (2019-07-17): Updated bank statement income. Buyer Comment (2019-07-16): Missing bank statements provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Missing the 3 months additional statements for $884.29 in income used by lender for XX18-XX18.

Reviewer Comment (2019-07-17): Updated bank statement income.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Missing the 3 months additional statements for $884.29 in income used by the lender for XX18-XX18.

Reviewer Comment (2019-07-17): Updated bank statement income.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 55.73923% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Missing the 3 months additional statements for $884.29 in income used by the lender for XX18-XX18.

Reviewer Comment (2019-07-17): Updated bank statement income.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902016

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.30209% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Reviewer Comment (2019-07-17): Updated bank statement income.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Fraud Report not provided

Reviewer Comment (2019-07-18): Fraud Report provided Buyer Comment (2019-07-17): Fraud report provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender exception for 50.265% please provided updated Lender exception at 50.51252%.

One open mortgage reporting 0x30 since inception XXXXXX. One closed mortgage reporting paid as agreed. Perfect credit history since inception of earliest account opened XXXXXX1. No public records. Borrower has employment stability for 10 years in the XXXXXX business 775 representative FICO score > 640 guideline minimum - 135 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-18): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-17): Updated XXXXXX Credit Exception uploaded for review. Reviewer Comment (2019-07-17): Most recent CBR dated XXXXXX reflects a pmnt of $146.00. Exception remains. Buyer Comment (2019-07-16): Please see trailing documents - XXXXXX pmnt should reflect 116, currently reflects 146.  Please clear.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

Insufficient asset documentation. Number of months asset statements verified is less than 2 months .

Reviewer Comment (2019-07-17): Updated assets for reserve requirement. Buyer Comment (2019-07-16): New account established 5/XXXX.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

-

No evidence of fraud report in file

Reviewer Comment (2019-07-18): Fraud Report not provided Buyer Comment (2019-07-17): Fraud report uploaded

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Non QM does not match Due Diligence Loan Designation of ATR loan

Reviewer Comment (2019-07-18): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-17): See trailing documents Reviewer Comment (2019-07-17): Most recent CBR dated XXXXXX reflects a pmnt of $146.00. Exception remains. Buyer Comment (2019-07-16): See trailing documents

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Based on the loan failing guidelines, the loan is at ATR risk

Reviewer Comment (2019-07-18): Client elects to waive the exception with verified compensation factors

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 50.51252% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Lender exception for 50.265% please provided updated Lender exception at 50.51252%.

One open mortgage reporting 0x30 since inception XXXXXX. One closed mortgage reporting paid as agreed. Perfect credit history since inception of earliest account opened XXXXXX1. No public records. Borrower has employment stability for 10 years in the XXXXXX business 775 representative FICO score > 640 guideline minimum - 135 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-18): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-07-17): See trailing documents Reviewer Comment (2019-07-17): Most recent CBR dated XXXXXX reflects a pmnt of $146.00. Exception remains. Buyer Comment (2019-07-16): See trailing documents

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

List of Homeownership Counseling Organizations not provided to the borrower

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided and incorrect amount that the Total Closing Costs exceeded the legal limit

Reviewer Comment (2019-07-18): Tolerance exceptions are addressed. Exception Cleared.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Your Home Loan Toolkit was not provided to the borrower

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Initial Loan Estimate electronically provided prior to borrowers consent to receive electronic disclosures,

Reviewer Comment (2019-07-18): E-consent provided. Buyer Comment (2019-07-17): Econsent provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on XXXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.

Loan Estimate provided prior to borrowers consent to receive electronically. Will not use for tolerance purposes.

Reviewer Comment (2019-07-18): E-consent provided. Buyer Comment (2019-07-17): Econsent uploaded

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller Closing Disclosure not provided

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

List of Service Providers not provided to the borrower

Reviewer Comment (2019-07-18): E-consent provided. Buyer Comment (2019-07-17): SSPL provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $565.25 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $565.25 exceeds tolerance of $0.00. Missing proof of valid change, a cure of $150.00 was provided at closing for Appraisal review fee

Reviewer Comment (2019-07-18): AMC received XX02 COC. Exception Cleared. Buyer Comment (2019-07-17): Valid CoC provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $585.00 exceeds tolerance of $435.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $585.00 exceeds tolerance of $435.00.  A cure of $150.00 was provided to the borrower for this overage, however, cure was insufficient to offset total overages.

Reviewer Comment (2019-07-18): A cure was provided on the final CD. Exception Cured.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902017

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing verification of ownership % as required by guides.

Reviewer Comment (2019-07-17): Business information provided Buyer Comment (2019-07-16): State Business information provided

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Do not require a CPA letter stating that the withdrawal of funds will not have a negative impact on the business vs program requirement to obtain a statement of funds stating that the withdrawal of funds will not have negative impact on the business.

One open mortgage reporting 0x30 since inception XXXXXX. One closed mortgage reporting paid as agreed. Perfect credit history since inception of earliest account opened XXXXXX1. No public records. Borrower has employment stability for 10 years in the XXXXXX business 775 representative FICO score > 640 guideline minimum - 135 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-15): Client has elected to waive this exception based on compensating factors.

07/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Reviewer Comment (2019-07-17): Updated assets for reserve requirement. Buyer Comment (2019-07-16): Asset statement provided, new account established with XXXXXX. Please clear.

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-07-17): Updated assets for reserve requirement and cash to close. Buyer Comment (2019-07-16): See trailing documents

07/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902017

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $585.00 exceeds tolerance of $435.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Qual Method differs from ATR, DTI is not Understated

Ability to Repay (Dodd-Frank 2014): The Qualification Method used by the lender does not match the ATR payment calculation methods under 1026.43(c)(5), but the method did not render a DTI that is less than that prescribed under ATR.

Used qualification method per investor guidelines.

Reviewer Comment (2019-07-16): Initial Loan Application in file.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

The final CD disclosed a finance charge of xxxx; calculated finance charge is $xxxx resulting in an under disclosure of $350.00. Due to the $350.00 PAD on the CD.

Reviewer Comment (2019-07-17): Letter of Explanation, Proof of Delivery, and Corrected CD provided.  PADS fee removed as borrower not charged the fee.  Confirmed from Settlement Statement

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure PAD Fee

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX disclosed a Pad fee that was not allocated to a specific cost or service performed.

The final CD disclosed an Escrow Pad of $350.00.

Reviewer Comment (2019-07-17): Letter of Explanation, Proof of Delivery, and Corrected CD provided.  PADS fee removed as borrower not charged the fee.  Confirmed from Settlement Statement

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Pad Refund Check if applicable, and Corrected CD

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD did not disclose a tolerance cure for the increase to the Escrow Pad.

Reviewer Comment (2019-07-17): Letter of Explanation, Proof of Delivery, and Corrected CD provided.  PADS fee removed as borrower not charged the fee.  Confirmed from Settlement Statement

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for PAD.  Fee Amount of $350.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Escrow Pad was added to the CD issued on XXXX19 without a valid change of circumstance.

Reviewer Comment (2019-07-17): Letter of Explanation, Proof of Delivery, and Corrected CD provided.  PADS fee removed as borrower not charged the fee.  Confirmed from Settlement Statement

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NMLS - Missing Evidence of Initial Loan Application Date

Truth in Lending Act (NMLSR Dodd- Frank 2014): Unable to determine compliance with NMLSR timing requirements due to missing evidence of initial loan application date.

Unable to determine compliance due to missing Creditor Application Date.

Reviewer Comment (2019-07-16): Initial Loan Application in file.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.

Unable to determine appropriate timing for disclosures due to missing Creditor Application Date.

Reviewer Comment (2019-07-16): Initial Loan Application in file.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.

Unable to determine appropriate timing for disclosures due to missing Creditor Application Date.

Reviewer Comment (2019-07-16): Initial Loan Application in file.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902018

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Missing Initial Loan Application Test

No evidence of application date located in file.  Compliance tests were run using an application date of XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.  The final date used for testing was XXXXXX

Reviewer Comment (2019-07-16): Initial Loan Application in file.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902019

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,854.85 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

207902019

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

207902019

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

207902020

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

The file contained documentation verifying the borrower was provided with a copy of the appraisal on XXXXXX, which is prior to the appraisal report date of XXXXXX. Evidence borrower received a copy of the revised appraisal was not provided.

Reviewer Comment (2019-07-29): Effective date is XXXXXX

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902020

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit disclosure was not provided to the borrower

Buyer Comment (2019-07-29): XXXXXX has elected to waive Reviewer Comment (2019-07-29): Documents provided in trailing docs are for wrong borrower and address.

07/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902020

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Interim Closing Disclosure Timing Irregular Transactions

TILA-RESPA Integrated Disclosure - Corrected Closing Disclosure provided on XXXXXX contains a change in APR, loan product or addition of prepayment penalty and was not received by borrower at least three (3) business days prior to consummation

Change in APR and borrower did not receive at least 3 business days prior to closing

Reviewer Comment (2019-07-29): Revised Initial CD provided

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902020

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller Closing Disclosure not in file

Reviewer Comment (2019-07-29): Seller Closing Disclosure Provided

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902020

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

ARM loan program disclosure not provided to the borrower

Reviewer Comment (2019-07-26): AMC received the ARM disclosure dated 6/5/19.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902020

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

CHARM booklet not provided to the borrower

Reviewer Comment (2019-07-26): AMC received the CHARM disclosure dated 6/5/19.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902020

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Reviewer Comment (2019-07-26): AMC received the home ownership counseling list dated 6/5/19.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902020

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

E-consent documents provided in trailing docs are for wrong borrower and address.

Reviewer Comment (2019-07-30): AMC received the E-consent for subject borrowers dated 6/5/19.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902021

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Purchase Agreement / Sales Contract not provided

Final reconciliation with final sales price on purchase contract missing. Purchase contract of $XXXXXX does not match 1008 or 1073 showing sales price of $XXXXXX

Reviewer Comment (2019-07-18): All documentation provided. Buyer Comment (2019-07-18): Page 2 of trailing documents denotes change to final sales price to match XXXXXX.  Uploaded document. Reviewer Comment (2019-07-18): Provide page/doc # where purXXXXXX amount of xxxx is referenced in file. Unable to locate. Buyer Comment (2019-07-17): See trailing documents

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

B

B

A

A

Non QM

Non QM

No

207902021

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final CD issued XXXX19 disclosed a closing date of XXXX19.  Actual date of consummation is XXXX19.

Buyer Comment (2019-07-17): XXXXXX has elected to waive this exception.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

B

B

A

A

Non QM

Non QM

Yes

207902023

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit missing

Buyer Comment (2019-07-18): XXXXXX has elected to waive

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902023

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller CD missing

Buyer Comment (2019-07-18): XXXXXX has elected to waive

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902023

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Engine Required. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-07-18): Compliance report provided.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902024

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

DTI of 54.39627% exceeds max allowed of 50% per guidelines.  Approved Lender Exception in file.

Self-employed XXXXXX for the past 25 years. Perfect mortgage history with a mortgage closed XXXXXX paid as agreed 58 months. Reserves of 45 months, 42 months > program requirement of 3 months. Credit score is 651, 11 points > program requirement of 640. LTV is 27.704%, 52.296% < program maximum of 80%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-17): Client has elected to waive this exception based on compensating factors.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-07-31): AMC received the signed and completed ATR attestation. Buyer Comment (2019-07-30): Attestation provided

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.91640% or Final Disclosure APR of 6.92200% is in excess of allowable threshold of APOR 3.87% + 1.5%, or 5.37000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-23): Compliant higher priced loan

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

Date of initial application is XXXX19 yet initial LE in file is dated XXXX19.

Reviewer Comment (2019-07-23): Initial LE provided Buyer Comment (2019-07-22): See Initial LE provided and subsequent COC's

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Administration Fee.  Fee Amount of $1,050.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXX19 did not reflect an Administration fee yet the final CD shows a charge of $1,050.

Reviewer Comment (2019-07-19): AMC received E consent dated XXXXXX. Exception Cleared.

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $90.00 exceeds tolerance of $87.00.  Insufficient or no cure was provided to the borrower.

Initial LE dated XXXX19 reflects a Tax Service Fee of $87 yet the final CD shows a charge of $90.

Reviewer Comment (2019-07-19): AMC received E consent dated XXXXXX. Exception Cleared.

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing documentation.

Reviewer Comment (2019-07-19): AMC received SSPL. Exception Cleared. Buyer Comment (2019-07-18): SSPL provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD does not reflect an amount by which the fees exceed the legal limit.

Reviewer Comment (2019-07-19): AMC received E consent dated XXXXXX. Exception Cleared.

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $6,878.05 and disclosure timing violations.

Missing documentation.

Reviewer Comment (2019-07-19): AMC received E consent dated XXXXXX. Exception Cleared. Buyer Comment (2019-07-18): Econsent provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

Property Tax under prepaids did not disclose number of months.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Missing documentation.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Timing

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Missing documentation.

Reviewer Comment (2019-07-23): Initial LE provided Buyer Comment (2019-07-22): Right to received Copy of Appraisal disclosure provided

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

Missing documentation.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 54.39627% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

DTI of 54.39627% exceeds max allowed of 50% per guidelines.  Approved Lender Exception in file.

Self-employed XXXXXX for the past 25 years. Perfect mortgage history with a mortgage closed XXXXXX paid as agreed 58 months. Reserves of 45 months, 42 months > program requirement of 3 months. Credit score is 651, 11 points > program requirement of 640. LTV is 27.704%, 52.296% < program maximum of 80%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-17): Client has elected to waive this exception based on compensating factors.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Additional Property Taxes Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Additional Property Taxes under Prepaids.

number of months not listed.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902024

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

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

AMC received SSPL dated XX12 however the application date is XX31.

Buyer Comment (2019-07-19): XXXXXX has elected to waive this exception.

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Reviewer Comment (2019-07-19): Executed Note provided Buyer Comment (2019-07-18): Executed Note provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Report not provided as required per final Loan Approval.

Reviewer Comment (2019-07-18): Compliance Report provided Buyer Comment (2019-07-18): Compliance report provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

207902025

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

53.687% DTI exceeds max allowed of 50% per guidelines.  Approved Lender Exception in file.

Perfect credit history with never a late payment, spanning 3 mortgages, with an earliest account inception date of XXXXXX and no public records. Borrower has been in the same line of work (XXXXXX) for the past 18 years. Credit score is 674, 34 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-17): Client has elected to waive this exception based on compensating factors.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Title policy amount of $320,000 is insufficient to cover loan amount of XXXXXX

Reviewer Comment (2019-07-26): AMC received the updated title supplement with proposed coverage of $322,000. Buyer Comment (2019-07-25): Updated Title provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing verbal verification of employment dated within 10 days of closing as required per final Loan Approval.

Reviewer Comment (2019-07-18): VVOE provided Buyer Comment (2019-07-18): VVOE provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Loan does not meet ATR requirements due to DTI and missing VVOE within 10 days of closing.

Reviewer Comment (2019-07-18): VVOE provided. Buyer Comment (2019-07-18): VVOE provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - W-2

Ability to Repay (Dodd-Frank 2014): Unable to verify current Wages/W-2 employment status using reasonably reliable third-party records.

Verbal VOE dated within 10 days of the Note was not provided.

Reviewer Comment (2019-07-18): VVOE provided. Buyer Comment (2019-07-18): VVOE provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 53.68735% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

53.687% DTI exceeds max allowed of 50% per guidelines.  Approved Lender Exception in file.

Perfect credit history with never a late payment, spanning 3 mortgages, with an earliest account inception date of XXXXXX and no public records. Borrower has been in the same line of work (XXXXXX) for the past 18 years. Credit score is 674, 34 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-17): Client has elected to waive this exception based on compensating factors.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Loan does not meet ATR requirements due to DTI exceeding program maximum.

Reviewer Comment (2019-07-18): VVOE provided.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-07-18): XXXXXX has elected to waive this exception.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The final CD disclosed that the loan is not assumable; the Note disclosed that the loan is assumable.

Buyer Comment (2019-07-18): XXXXXX has elected to waive this exception.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

The premium disclosed in Section F of the final CD included a $25.00 fee in addition to the annual premium.

Buyer Comment (2019-07-18): XXXXXX has elected to waive this exception.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Reviewer Comment (2019-07-18): Discloure provided. Buyer Comment (2019-07-18): CHARM disclosure provided

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Approved exception to exclude xxxx auto installment loan payment of $626 per month with only 9 months proof of payment being made by another person due to account opened XXXX vs program requirement of 12 months proof of payments being made by a third party to exclude debt from ratios (DTI is 51.94% with exclusion of loan and would be 66.386% with inclusion of loan).

Perfect credit history with never a late payment, spanning 3 mortgages, with an earliest account inception date of XXXXXX and no public records. Borrower has been in the same line of work (XXXXXX) for the past 18 years. Credit score is 674, 34 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-17): Client has elected to waive this exception based on compensating factors.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

C

B

D

B

A

A

Non QM

Non QM

No

207902025

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Reviewer Comment (2019-07-19): VVOE provided. Buyer Comment (2019-07-18): VVOE provided Buyer Comment (2019-07-18): See prior trailing documents provided - ATR - XXXXXX Credit Exception provided

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

207902026

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Missing loan approval and 1008 with DTI at 44.234%.

Reviewer Comment (2019-08-02): Loan Approval and 1008 provided on XXXXXX show DTI of 42.912%. DTI of 44.234% includes a payment of $575 for XXXXXX with an outstanding balance of $575. Account excluded per guidelines.  All non-medical collection accounts and charge-offs exceeding $1000, which are not in dispute (except collection accounts and charge offs no longer enforceable due to the applicable state statute of limitations), must be paid in full prior to or at the time of a Loans' funding by the originating lender.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Reviewer Comment (2019-07-26): ARM disclosure provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Tax Service Fee (Life Of Loan).  Fee Amount of $80.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Tax Service fee was added to the LE issued on XXXX19 without a valid change of circumstance.

Reviewer Comment (2019-07-22): AMC received required documents, exception is cleared.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Provided Through Home Loan Toolkit

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet provided to the borrower through Home Loan Toolkit.

Reviewer Comment (2019-07-26): CHARM disclosure provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD did not provide a tolerance cure of $430.00 for the increases to the Underwriting Fee and Tax Service Fee.

Reviewer Comment (2019-07-26): Tolerance exceptions are addressed. Exception Cleared. Reviewer Comment (2019-07-22): Changed circumstance from 6/XXXX does not show reason for increase in underwriting fees by $350. A PCCD, LOE, copy of the refund check in the amount of $350 and proof of delivery is required in order to address the exception. Buyer Comment (2019-07-19): Please see uploaded LE, COC, and CD

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $1,540.00 exceeds tolerance of $1,190.00.  Insufficient or no cure was provided to the borrower.

The LE issued on XXXX19 increased the Underwriting Fee without a valid change of circumstance.

Reviewer Comment (2019-07-26): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Reviewer Comment (2019-07-22): Changed circumstance from 6/XXXX does not show reason for increase in underwriting fees by $350.  A PCCD, LOE, copy of the refund check in the amount of $350 and proof of delivery is required in order to address the exception. Buyer Comment (2019-07-19): Please see uploaded LE, COC, and CD

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902026

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Aside from disputed cell phone collection account for $575, borrower had had no credit late payments in the past 48 months (since XXXXXX) and no public records. Borrower has been XXXXXX for the past 6 years. FICO score is 677, 17 points > 660 program requirement.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-01): Client elects to waive the exception with verified compensation factors. Reviewer Comment (2019-07-31): Documentation sent was not received. Please resubmit.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902026

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Transaction Error: Outstanding liens were not paid at closing.

Approved exception to allow XX taxes due to remain unpaid as Borrower has payment plan with IRS vs program requirement that all outstanding taxes due must be paid in full prior to or at closing.

Aside from disputed cell phone collection account for $575, borrower had had no credit late payments in the past 48 months (since XXXXXX) and no public records. Borrower has been XXXXXX for the past 6 years. FICO score is 677, 17 points > 660 program requirement.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-17): Client has elected to waive this exception based on compensating factors.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902026

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Underwriting Fee.  Fee Amount of $1,540.00 exceeds tolerance of $1,190.00.  Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2019-07-26): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

07/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Closing / Title

Missing Document: Note - Subject Lien not provided

Reviewer Comment (2019-07-31): Note - Subject Lien provided

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Loan Underwriting and Transmittal Summary (1008) / MCAW not provided

Reviewer Comment (2019-07-24): AMC received the 1008 dated 7/XX19.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Reviewer Comment (2019-07-24): AMC received the homeownership counseling disclosure dated 7/XX19.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Prior to Closing Timing

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower at least three (3) days prior to consummation for a loan that did not start as an ARM.

The only ARM disclosure provided in file was signed day of closing. No evidence that disclosure was provided to Borrower within 3 days of loan application.

Reviewer Comment (2019-07-26): LE's provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Reviewer Comment (2019-07-24): AMC received the Home loan toolkit dated 4/XX19.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Right to receive a copy of the appraisal is missing from file

Reviewer Comment (2019-07-26): LE's provided Reviewer Comment (2019-07-25): Exception is related to not having any of the LE's in the file.  Please provided Initial LE and all subsequent LE's issued to the borrower.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

The SSPL disclosure is missing from file

Reviewer Comment (2019-07-26): LE's provided Buyer Comment (2019-07-25): Please see uploaded SSPL and LEs Reviewer Comment (2019-07-25): Exception is related to not having any of the LE's in the file.  Please provided Initial LE and all subsequent LE's issued to the borrower.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

It is assumed that assumption is allowed based upon the fact the subject loan is an ARM, however, the Note is missing from file so it cannot be confirmed.

Buyer Comment (2019-07-30): XXXXXX has elected to waive

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit is not located in file

Reviewer Comment (2019-07-24): AMC received the Home Loan Toolkit dated 4/XX19.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Final CD is dated XXXX19, and not provided to borrower at least three business day prior to closing. Date of closing is XXXX19

Reviewer Comment (2019-07-26): Initial CD provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $20,687.88 may be required.

Loan Estimate is not located in file.  Final CD used to establish the baseline for tolerance testing.

Reviewer Comment (2019-07-26): LE's provided Buyer Comment (2019-07-25): Please see uploaded SSPL and LEs

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller's Closing Disclosure (CD) missing from file

Reviewer Comment (2019-07-30): Seller's CD provided. Reviewer Comment (2019-07-25): Please provide Seller CD, it was not provided in the trailing documents

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

Note is missing from file.  Data entry for Adjustable Rate mortgage adjustments taken from Final CD and Rate Lock Confirmation.

Buyer Comment (2019-07-30): XXXXXX has elected to waive

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Title Error: Title vesting does not concur with deed

The Security Instrument vesting lists the Borrower as "XXXXXX" while the recorded deed provided from time of closing discloses vesting of "XXXXXX".

Reviewer Comment (2019-07-26): A recorded Name Affidavit for the borrower was provided.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Provided Through Home Loan Toolkit

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet provided to the borrower through Home Loan Toolkit.

Reviewer Comment (2019-07-30): Home Loan Toolkit provided.  CHARM is a part of it.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

1003 in the loan file has an application date of XXXXXX.  Loan Estimate provided have issue dates of XXXXXX and XXXXXX.  LE not provided within 3 days of application date.

Reviewer Comment (2019-07-30): Initial LE provided.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

1003 in the loan file has an application date of XXXXXX.  Loan Estimate provided have issue dates of XXXXXX and XXXXXX.  LE not provided within 3 days of application date.

Reviewer Comment (2019-07-30): Initial LE provided.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Timing

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

1003 in the loan file has an application date of XXXXXX.  Loan Estimate provided have issue dates of XXXXXX and XXXXXX.  LE not provided within 3 days of application date.

Reviewer Comment (2019-07-30): Initial LE provided.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/7/XX 12:00:00 AM was received.

Initial CD signed by borrower on XXXXXX.  Please provide proof of receipt for the LE issued XXXXXX.  AMC is currently using the mailbox rule for receipt date for this LE

Buyer Comment (2019-07-30): XXXXXX has elected to waive Reviewer Comment (2019-07-30): Evidence of earlier receipt for revised LE issued on 6/4/19 was not found. Buyer Comment (2019-07-29): Please see uploaded LE's

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 6/7/XX 12:00:00 AM was received.

Initial CD signed by borrower on XXXXXX.  Please provide proof of receipt for the LE issued XXXXXX.  AMC is currently using the mailbox rule for receipt date for this LE

Buyer Comment (2019-07-30): XXXXXX has elected to waive Reviewer Comment (2019-07-30): Evidence of earlier receipt for revised LE issued on 6/6/19 was not found. Buyer Comment (2019-07-29): Please see uploaded LE's

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

1003 in the loan file has an application date of XXXXXX.  Loan Estimate provided have issue dates of XXXXXX and XXXXXX.  LE not provided within 3 days of application date.

Reviewer Comment (2019-07-30): Initial LE provided. Buyer Comment (2019-07-29): Please see uploaded LE's

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

C

A

D

B

A

A

Non QM

Non QM

No

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

.

Reviewer Comment (2019-07-30): Valid COC provided.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $8,000.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

.

Reviewer Comment (2019-07-30): Valid COC provided.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902027

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $700.00.  Insufficient or no cure was provided to the borrower.

.

Reviewer Comment (2019-07-30): Valid COC provided.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

C

A

D

B

A

A

Non QM

Non QM

Yes

207902028

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Borrower ability to repay attestation not provided

Reviewer Comment (2019-07-23): Ability to repay provided

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Loan amount of XXXXXX  exceeds max allowed of $2,500,000.  Approved Lender Exception in file.

Reserves are 29 months, 13 months > program requirement of 16 months (12 months plus 4 months for 2 mortgaged investment properties). Borrower has 1 closed and 2 open mortgages reporting 0x30 since earliest inception date 8/2007 (1 isolated 30 day in 1/2015).  All other credit accounts reporting paid as agreed. Borrower has been XXXXXX for the past 15 years.  In addition, he has 19 years XXXXXX DTI is 29.104%, 20.896% < program maximum of 50%. Credit score is 756, 76 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-17): Client has elected to waive this exception based on compensating factors.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Valuation provided to borrower on XXXX19 yet date of appraisal is XXXX19.

Buyer Comment (2019-07-19): XXXXXX has elected to waive

07/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing evidence borrower was provided the Appraisal disclosure at time of application.

Reviewer Comment (2019-07-22): Initial LE provided

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Non QM does not match Due Diligence Loan Designation of ATR fail

Reviewer Comment (2019-07-23): AMC received the 1040 XX's e-signature authorization by borrower - 1040's signed by the preparer. Buyer Comment (2019-07-19): This is a partnership, please refer to tax returns and uploaded business search

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - Partnership Test

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current Partnership status using reasonably reliable third-party records.

Unable to verify current Partnership status using reliable third party source

Reviewer Comment (2019-07-22): Third party verification of self employment provided

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Partnership

Ability to Repay (Dodd-Frank 2014): Unable to verify Partnership income using reasonably reliable third-party records.

Unable to verify Partnership income using reliable third party source

Reviewer Comment (2019-07-23): AMC received the 1040 XX's e-signature authorization by borrower - 1040's signed by preparer. Buyer Comment (2019-07-22): Please see uploaded documents Buyer Comment (2019-07-19): This is a partnership, please refer to tax returns and uploaded business search

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Partnership

Ability to Repay (Dodd-Frank 2014): Unable to verify Partnership income using reasonably reliable third-party records.

Unable to verify Partnership income using reliable third party source

Reviewer Comment (2019-07-23): AMC received the 1040 XX's e-signature authorization by borrower - 1040's signed by the preparer. Buyer Comment (2019-07-22): Please see uploaded documents Buyer Comment (2019-07-19): This is a partnership, please refer to tax returns and uploaded business search

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Unable to verify S-Corp income using reliable third party source

Reviewer Comment (2019-07-23): AMC received the 1040 XX's e-signature authorization by borrower - 1040's signed by preparer. Buyer Comment (2019-07-22): Please see uploaded documents Buyer Comment (2019-07-19): This is a partnership, please refer to tax returns and uploaded business search

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Unable to verify S-Corp income using reliable third party source

Reviewer Comment (2019-07-23): AMC receive the 1040 XX's e-signature authorization by borrower - 1040's signed by preparer. Buyer Comment (2019-07-22): Please see uploaded documents Buyer Comment (2019-07-19): This is a partnership, please refer to tax returns and uploaded business search

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Schedule C

Ability to Repay (Dodd-Frank 2014): Unable to verify Sole Proprietorship income using reasonably reliable third-party records.

Unable to verify Sole Proprietorship income using reliable third party source

Reviewer Comment (2019-07-23): AMC received the 1040 XX's e-signature authorization by borrower - 1040's signed by pre-parer. Buyer Comment (2019-07-22): Please see uploaded documents Buyer Comment (2019-07-19): This is a partnership, please refer to tax returns and uploaded business search

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Ability to repay requirements not satisfied due to missing third party verification of borrower's self employment income.

Reviewer Comment (2019-07-23): AMC received the 1040 XX's e-signature authorization by borrower - 1040's signed by pre-parer.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

List of Homeownership Counseling Organizations not provided to the borrower

Reviewer Comment (2019-07-19): AMC received the Homeownership counseling disclosure dated 4/XX19.

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit disclosure not provided ot the borrower

Reviewer Comment (2019-07-19): AMC received the disclosure tracking for the Home loan toolkit dated 4/XX19.

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided to borrower at least 3 business days before closing

Reviewer Comment (2019-07-22): Initial CD provided

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $32,368.80 may be required.

Missing copy of Loan Estimate.

Reviewer Comment (2019-07-22): Initial LE provided

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

ARM Disclosure not provided to borrower within 3 days of application

Reviewer Comment (2019-07-23): Loan was disclosed as a fixed rate at time of application and changed to an ARM on the 6/XX19 CD - ARM disclosure dated 6/XX19 within 3 days of change.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

CHARM booklet not provided to the borrower

Reviewer Comment (2019-07-19): AMC received the disclosure tracking for the Home loan toolkit dated 4/XX19.

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Borrower provided with Servicing Disclosure

Reviewer Comment (2019-07-22): Initial LE provided

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902028

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

-

Allow loan to close with IRS Tax lien in a repayment plan vs. program requirement that borrowers must not be subject to a lien that may attach to the subject property.  Approved Lender Exception in file.

Reserves are 29 months, 13 months > program requirement of 16 months (12 months plus 4 months for 2 mortgaged investment properties). Borrower has 1 closed and 2 open mortgages reporting 0x30 since earliest inception date 8/2007 (1 isolated 30 day in 1/2015).  All other credit accounts reporting paid as agreed. Borrower has been XXXXXX for the past 15 years.  In addition, he has 19 years XXXXXX DTI is 29.104%, 20.896% < program maximum of 50%. Credit score is 756, 76 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-17): Client has elected to waive this exception based on compensating factors.

07/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Provided Through Home Loan Toolkit

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet provided to the borrower through Home Loan Toolkit.

Buyer Comment (2019-07-22): XXXXXX has elected to waive

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902028

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $196.00 exceeds tolerance of $168.00 plus 10% or $184.80.  Sufficient or excess cure was provided to the borrower at Closing.

$11.20 cure provided at closing.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902029

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Report not provided.

Reviewer Comment (2019-07-18): Compliance Report provided.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

A

A

C

A

B

A

Non QM

Non QM

Yes

207902029

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Missing appraisal transfer letter

Reviewer Comment (2019-07-24): AMC received the appraisal transfer letter dated 6/XX19 to XXXXXX

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

A

A

C

A

B

A

Non QM

Non QM

No

207902029

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD did not provide a tolerance cure for the increase to the Endorsement Fee.  Due to missing provider list, unable to determine if vendor was on the list.

Reviewer Comment (2019-07-19): fees paid to borrower chosen provider - no tolerance testing Buyer Comment (2019-07-18): Please see uploaded SSPL and Fees in Section C - borrower can shop for , as such there is no tolerance for the endorsement fee that borrower shop fro - no cost to cure required

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

A

A

C

A

B

A

Non QM

Non QM

Yes

207902029

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

The provider list was included in the disclosure list; however, the document was not provided so unable to determine if it was compliant and if any listed vendors were used.

Reviewer Comment (2019-07-18): Settlement Service Provider  list provided.

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

A

A

C

A

B

A

Non QM

Non QM

No

207902029

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Endorsement Fee was added to the CD issued on XXXX19 without a valid change of circumstance.

Reviewer Comment (2019-07-19): fees paid to borrower chosen provider - no tolerance testing Buyer Comment (2019-07-18): Fees in Section C - borrower can shop for , as such there is no tolerance for the endorsement fee that borrower shop fro - no cost to cure required

07/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

A

A

A

C

A

B

A

Non QM

Non QM

Yes

207902030

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Approved lender exception doc 374 for DTI of 52.06% vs. program max 50%.

Borrower's overall monthly debt payment decreased by $3,389 per month with this refinance 1 open mtg. paid as agreed since 9/2012, no late payments in past 63 months, no public records. Borrower self-employed for past 3.42 years, in line of business 5 years. 25 months reserves vs. program required 3 months. 741 credit score vs. program min 700 57.69% LTV vs. program max 85%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-22): Client has elected to waive this exception based on compensating factors.

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

B

A

Non QM

Non QM

No

207902030

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(TX50(a)(6)) Texas Cash-out Loan (T-42 Endorsement Not Obtained)

XXXXXX Constitution Section 50(a)(6): Acceptable FNMA title insurance endorsements not obtained for home equity loan.  The loan file does not evidence the Title Policy includes the XXXXXX T-42 endorsement or the T-42.1 endorsement. (The loan is a XXXXXX Section 50 (a)(6) home equity loan.)

Buyer Comment (2019-07-24): waive

07/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

The endorsements would be required at the time of original title policy issuance, there is not an obvious remediation

C

B

B

B

C

B

B

A

Non QM

Non QM

No

207902030

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(TX50(a)(6)) Texas Cash-out Loan  (Acknowledgment of Fair Market Value Disclosure Not Signed by the Lender)

XXXXXX Constitution Section 50(a)(6): Acknowledgment of the Fair Market Value not properly executed by the Lender.

Reviewer Comment (2019-07-24): Fair Market Value Disclosure signed by the lender.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

To Remediate: Lender must either sign the AFMV.  Best practices would be to deliver to the borrower the required disclosure signed by the lender or refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree.

C

B

B

B

C

B

B

A

Non QM

Non QM

Yes

207902030

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(TX50(a)(6)) Texas Cash-out Loan  (Itemization of Points and Fees Not Provided)

XXXXXX Constitution Section 50(a)(6): Final Itemized disclosure of fees, points, costs and charges not provided to borrower.

Reviewer Comment (2019-07-24): CD issued XXXXXX provided

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Refund or credit the borrower $1,000 and offer the borrower the right to refinance the extension of credit for the remaining term of the loan at no cost to the borrower on the same terms, including interest, as the original extension of credit with any modifications necessary to comply with this section or on terms on which the borrower and the lender or holder otherwise agree.

C

B

B

B

C

B

B

A

Non QM

Non QM

Yes

207902030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-23): waive

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

B

A

Non QM

Non QM

No

207902030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-07-23): waive

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

B

A

Non QM

Non QM

No

207902030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

ATR fail due to missing third party verification of S-Corp business.

Reviewer Comment (2019-07-24): Third Party Verification provided Buyer Comment (2019-07-23): uploaded business search

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

B

B

B

C

B

B

A

Non QM

Non QM

Yes

207902030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - S-Corp Test

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status using reasonably reliable third-party records.

Missing third party verification of start date for S-Corp business.

Reviewer Comment (2019-07-24): Third party verification provided

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

B

A

Non QM

Non QM

No

207902030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.06027% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Approved lender exception doc 374 for DTI of 52.06% vs. program max 50%.

Borrower's overall monthly debt payment decreased by $3,389 per month with this refinance 1 open mtg. paid as agreed since 9/2012, no late payments in past 63 months, no public records. Borrower self-employed for past 3.42 years, in line of business 5 years. 25 months reserves vs. program required 3 months. 741 credit score vs. program min 700 57.69% LTV vs. program max 85%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-22): Client has elected to waive this exception based on compensating factors.

07/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

B

A

Non QM

Non QM

No

207902030

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

ATR fail due to missing third party verification of S-Corp business.

Reviewer Comment (2019-07-24): Third party verification provided

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

B

A

Non QM

Non QM

No

207902030

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Appraisal transfer in file is from XXXX Mortgage, the broker on file, not lender on file.  Provide appraisal transfer to lender shown on note.

Reviewer Comment (2019-07-29): AMC received the appraisal transfer letter from XXXX dated 4/XX19.

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

B

A

Non QM

Non QM

No

207902031

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower.

Reviewer Comment (2019-07-25): AMC received the NY Subprime counseling disclosure dated 3/XX19.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902031

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.80230% or Final Disclosure APR of 7.86300% is in excess of allowable threshold of Prime Mortgage Market Rate 3.82000 + 1.75%, or 5.57000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-07-25): AMC received the NY Subprime counseling disclosure dated 3/XX19.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902031

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

A dollar amount by which costs exceeded legal limits is not disclosed.

Reviewer Comment (2019-07-25): COC and Revised CD provided - Rate lock extension Buyer Comment (2019-07-24): The CD CIC was for the rate lock was disclosed on 7/2.  It was wet-signed- see attached. It looks like you reviewed the CD from 7/9- which was the at closing CD. Reviewer Comment (2019-07-24): Cure required.  Change was received on 7/2/XX, and should have been disclosed by 7/8.   The changes were not disclosed until 7/9.  Barring any undocumented circumstances,  A PCCD, LOE, copy of the refund check in the amount of $646.87 and proof of delivery is required in order to address the exception.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902031

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller CD is missing from loan file.

Reviewer Comment (2019-07-24): AMC received required documents, exception is cleared.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902031

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $11,126.25 exceeds tolerance of $9,056.00.  Insufficient or no cure was provided to the borrower.

Evidence of sufficient cure for increase in discount points not provided.

Reviewer Comment (2019-07-24): Upon further review, the exception is cleared.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902031

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Extension Fee.  Fee Amount of $646.87 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Evidence of sufficient cure for increase in lock extension fee not provided.

Reviewer Comment (2019-07-25): COC and Revised CD provided - Rate lock extension Buyer Comment (2019-07-24): The CD CIC was for the rate lock was disclosed on 7/2.  It was wet-signed- see attached. It looks like you reviewed the CD from 7/9- which was the at closing CD. Reviewer Comment (2019-07-24): Cure required.  Change was received on 7/2/XX, and should have been disclosed by 7/8.   The changes were not disclosed until 7/9.  Barring any undocumented circumstances,  A PCCD, LOE, copy of the refund check in the amount of $646.87 and proof of delivery is required in order to address the exception.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902031

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.80230% or Final Disclosure APR of 7.86300% is in excess of allowable threshold of Prime Mortgage Market Rate 3.82000 + 1.75%, or 5.57000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-25): XXXXXX has elected to waive

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902034

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

Missing verification of mortgage (VOM) for XXXXXX new mortgage (XXXXXX) that funded on XXXXXX in the amount of $xxxx.

Reviewer Comment (2019-07-23): AMC received the VOM reflecting 0x30 for 4/XX and 5/XX.

07/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902034

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: Closing Disclosure is incomplete

CD dated XXXX19 incomplete pages 1,2, 5

Reviewer Comment (2019-07-26): The CD dated 6/XX19 was not provided to the consumers and only used to confirm fees. CD has been excluded from consideration.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.27700% or Final Disclosure APR of 7.33500% is in excess of allowable threshold of APOR 3.87% + 1.5%, or 5.37000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-25): Appraisal delivery certificate provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD page 3 in the section by which the closing costs exceed the legal limit is blank. Amount to cure is $780.00. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-07-24): Upon further review, the exception is cleared. Reviewer Comment (2019-07-24): Final CD page 3 in the section by which the closing costs exceed the legal limit is blank. Amount to cure is $475.00. No evidence in file that cure was provided to borrower. Buyer Comment (2019-07-23): please see uploaded documents

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $475.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Second Appraisal Fee added of $475.00 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure was provided to Borrower.

Reviewer Comment (2019-07-24): Upon further review, the exception is cleared.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges.  Fee Amount of $305.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Title - Service Charge Fee was added of $305.00 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure was provided to Borrower.

Reviewer Comment (2019-07-24): Fee was paid to same provider on the CD and not listed on the LE - no tolerance. Buyer Comment (2019-07-23): Please see uploaded documents

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-25): Appraisal delivery certification provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902034

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-25): Appraisal delivery certificate provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902034

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-07-26): Sourced earnest money deposit in amount of $5,000 added to closing funds.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902035

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

DTI of 56.55489% exceeds max of 50% allowed per guidelines.  Lender excluded the Lend updebt for $25 a month with $183  balance and xxxx for $343 a month $6,960 balance no proof of payoffs. Please provide updated lender exception at 56.55489%.

No public records. Borrower has been self-employed for the past 2 years as XXXXXX, in the same line of business for the past 5 years. Reserves are 89 months, 86 months > program requirement of 3 months. Credit score is 694, 44 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-29): Client elects to waive the exception with verified compensation factors. Buyer Comment (2019-07-26): XXXXXX to XXXXXX Reviewer Comment (2019-07-25): Printout from XXXXXX dated XXXXXX does not include identifying information to indicate that it is now under a new name. Also, the monthly payment used for qualifying on the XXXXXX account is $25.00. Excluding the $25 payment results in a DTI of 52.244223%. Provide additional documentation to confirm that the account was paid prior to closing. If there are no other changes to the borrower's debts prior to closing, a lender exception will be required for the DTI exceeding the guidelines.  Without any additional adjustments, the DTI is 52.53521%. Buyer Comment (2019-07-24): XXXXXX is now XXXXXX proof of 0 balance Reviewer Comment (2019-07-24): Credit report shows XXXXXX as of XXXX. A copy of the borrower's account showing the withdrawal of the funds payable to XXXXXX for $6,662.19 on XXXXXX and a print out from the XXXXXX website shows that as of XXXXXX the account was paid in full prior to the closing date of XXXXXX. Documents submitted did not include proof of payoff of the XXXXXX account. Recalculated DTI is 52.53521% that still exceeds the guidelines maximum of 50%. Buyer Comment (2019-07-23): COC for loan amount change,LE 7/8, XXXXXX proof of payoff

07/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902035

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902035

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

DTI of 56.55489% exceeds max of 50% allowed per guidelines.  Lender excluded the Lend updebt for $25 a month with $183  balance and xxxx for $343 a month $6,960 balance no proof of payoffs. Please provide updated lender exception at 56.55489%.

Reviewer Comment (2019-07-29): Client elects to waive the exception with verified compensation factors.

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902035

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 56.55489% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

DTI of 56.55489% exceeds max of 50% allowed per guidelines.  Lender excluded the Lend updebt for $25 a month with $183  balance and xxxx for $343 a month $6,960 balance no proof of payoffs. Please provide updated lender exception at 56.55489%.

Reviewer Comment (2019-07-24): DTI adjusted due to credit debt per paid off statement for lending club account received by AMC.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902035

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI of 56.55489% exceeds max of 50% allowed per guidelines.  Lender excluded the Lend updebt for $25 a month with $183  balance and xxxx for $343 a month $6,960 balance no proof of payoffs. Please provide updated lender exception at 56.55489%.

Reviewer Comment (2019-07-29): Client elects to waive the exception with verified compensation factors.

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902035

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

A dollar amount by which costs exceeded legal limits was not disclosed.

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902035

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-4,628.25  is less than amount of binding Lender Credit previously disclosed in the amount of $-5,623.00.

LE dated XXXX19 reflects a Lender Credit in the amount of $5,623 yet the final CD shows a credit of only $4,628.25.

Reviewer Comment (2019-07-24): Revised LE and COC provided - Revised LE also had a reduction in rate as well as loan amount change. Buyer Comment (2019-07-23): COC for loan amount change,LE 7/8 Buyer Comment (2019-07-23): COC for loan amount change

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902035

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.53521% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

No public records. Borrower has been self-employed for the past 2 years as XXXXXX, in the same line of business for the past 5 years. Reserves are 89 months, 86 months > program requirement of 3 months. Credit score is 694, 44 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-29): Client elects to waive the exception with verified compensation factors.

07/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902036

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Missing evidence borrower was provided the List of Homeownership Counseling Organizations to borrower at time of application.

Reviewer Comment (2019-07-24): AMC received the Homeownership counseling list dated 5/XX19.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902036

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Initial LE dated XXXX19 was electronically signed by the borrower on XXXX19 yet E-Consent Disclosure missing from the loan file.

Reviewer Comment (2019-07-24): AMC received required documents, exception is cleared.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902036

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $8,065.20 and disclosure timing violations.

E-Sign Consent form missing. May result in a fee tolerance violation.

Reviewer Comment (2019-07-24): AMC received required documents, exception is cleared.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902036

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence borrower was provided the Home Loan Toolkit to borrower at time of application.

Reviewer Comment (2019-07-24): AMC received the disclosure tracking receipt of the Home loan toolkit on 5/XX19 via electronic disclosure - the e-consent was also provided as signed on 5/XX19.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902036

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Final CD issued XXXX19 was not provided to Borrower at least three business days prior to closing. Closing date is XXXX19

Reviewer Comment (2019-07-24): AMC received required documents, exception is cleared.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902036

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing evidence borrower was provided the Settlement Service Provider List to borrower at time of application.

Reviewer Comment (2019-07-24): AMC received required documents, exception is cleared.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902037

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Final Title Policy not provided. Commitment in file reflected $400,000 policy amount

Reviewer Comment (2019-07-25): AMC received the revised/updated title commitment for $440,000 in proposed policy amount.

07/25/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902037

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

-

Fraud report not in file

Reviewer Comment (2019-07-25): AMC received the Fraud report dated 6/XX19.

07/25/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902037

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Note Error: Zip code is blank.

Note incorrectly reflects zip code of xxxxx vs. correct zip code of xxxxx.

Reviewer Comment (2019-07-25): AMC received the allonge and corrected Note with zip code xxxx.

07/25/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902037

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Security Instrument Error: Zip is blank was not provided

Security Instrument incorrectly reflects zip code of xxxxx vs. correct zip code of xxxxx

Reviewer Comment (2019-07-25): AMC received the allonge and corrected Security Instrument with zip code xxxxx.

07/25/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902038

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Used XX Schedule E in lieu of the fact that an extension was filed for XX. Copy of XX lease agreements in file also supports income used.Missing XX 1040 as this is most recent. Extension expired. If the Date of the Loan is after April 15 of a given year, then the needed return(s) are the return(s) for the calendar year most recently ended.

Reviewer Comment (2019-07-25): XX extension located in file and tax transcripts for 20XXXX were pulled.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902038

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - REO Schedule E Method Test

Ability to Repay (Dodd-Frank 2014): Unable to verify Real Estate Owned income (Schedule E Method) using reasonably reliable third-party records.

Used XX Schedule E in lieu of the fact that an extension was filed for XX. Copy of XX lease agreements in file also supports income used.Missing XX 1040 as this is most recent. Extension expired. If the Date of the Loan is after April 15 of a given year, then the needed return(s) are the return(s) for the calendar year most recently ended.

Reviewer Comment (2019-07-25): XX extension located in file and tax transcripts for 20XXXX were pulled.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902038

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Non QM Loan

Reviewer Comment (2019-07-25): XX extension located in file and tax transcripts for 20XXXX were pulled.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902038

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-07-25): XXXXXX has elected to waive

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902038

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower within three days of application.

Disclosure dated XXXX19 application date XXXX19.

Reviewer Comment (2019-07-25): Counseling Disclosure dated XXXXXX provided.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902038

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Subprime Legend Not on Mortgage)

XXXXXX Subprime Loan:  Mortgage does not contain a legend stating that the subprime loan is subject to Section 6-m of the Banking Law.

Missing Subprime Legend.

Reviewer Comment (2019-07-25): Revised mortgage with the legend and an intent to re-record letter provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Provide the following:  Letter of Explanation,  corrected Mortgage (with required Legend), and proof of mailing.  Best Practice would be to have signed and re-recorded Mortgage. (This will overwrite the existing Exception Remediation which reads: Provide the following: Corrected Mortgage (with required Legend), Letter of Explanation, and Proof of Delivery.  Best Practice would be to have signed and re-recorded Mortgage.).

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902038

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.34890% or Final Disclosure APR of 7.39600% is in excess of allowable threshold of Prime Mortgage Market Rate 4.12000 + 1.75%, or 5.87000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-07-25): Counseling Disclosure and Mortgage with legend provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902038

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Closing Costs Financed

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.

Fees entered as reported

Buyer Comment (2019-07-25): XXXXXX has elected to waive

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902038

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $625.00 exceeds tolerance of $600.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902038

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing XX 1040 as this is most recent. Extension expired. If the Date of the Loan is after April 15 of a given year, then the needed return(s) are the return(s) for the calendar year most recently ended.

Reviewer Comment (2019-07-25): Extension in file for XX tax return - 1040 not required.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902038

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.34890% or Final Disclosure APR of 7.39600% is in excess of allowable threshold of Prime Mortgage Market Rate 4.12000 + 1.75%, or 5.87000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-25): XXXXXX has elected to waive

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902038

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Disclosure provided XXXXXX

Buyer Comment (2019-07-25): XXXXXX has elected to waive

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902039

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Page 4 of the final CD indicates loan assumption is not allowed yet the Note reflects loan assumption verbiage.

Buyer Comment (2019-07-24): XXXXXX has elected to waive

07/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207902039

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Missing signed Borrower Ability to Repay Attestation as required per guidelines.

Reviewer Comment (2019-07-25): AMC receive the signed and initialed Borrower attestation for all 3 borrowers dated 7/XX19.

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902040

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

-

Reviewer Comment (2019-07-24): AMC received the PitchPoint fraud report as per client this is an acceptable fraud prevention engine. Reviewer Comment (2019-07-24): AMC received the Borrower results from PitchPoint. Per guides fraud prevention engine pull must be obtained from either DataVerify, CoreLogic, SAS - or from another fraud prevention engine which XXXXXX, in its discretion, chooses to accept. Each high-risk alert indicated by the engine pull must be addressed by the Lender.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902040

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.12370% or Final Disclosure APR of 7.19500% is in excess of allowable threshold of Prime Mortgage Market Rate 3.84000 + 1.75%, or 5.59000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-24): XXXXXX has elected to waive

07/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902041

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-07-29): Borrower ATR Attest provided Buyer Comment (2019-07-26): Borrower ATR Attest provided

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902041

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

Maryland Counseling Agencies Disclosure Not in File

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

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902041

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

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

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

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902041

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX HPML Threshold Test Non-Compliant

XXXXXX Higher-Priced Mortgage Loan: APR on subject loan of 7.60190% or Final Disclosure APR of 7.64500% is in excess of allowable threshold of APOR 3.87% + 1.5%, or 5.37000%.  Non-Compliant Higher Priced Loan.

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Total Closing Cost exceeded the legal limit.

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing documentation

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902041

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,482.00 exceeds tolerance of $936.00 plus 10% or $1,029.60.  Insufficient or no cure was provided to the borrower.

Final disclosure reflects an increase in ten percent tolerance fees exceeding the legal limit. This includes fees paid by the seller at closing. No cure provided at closing

Reviewer Comment (2019-07-29): AMC received the SSPL dated 5/XX19. Buyer Comment (2019-07-26): See SSPL provided

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902041

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing verification of ownership % as required by the guides.

Reviewer Comment (2019-07-24): CPA letter dated XXXXXX confirms ownership of the business as 100% Buyer Comment (2019-07-23): CPA letter provided

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902042

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Loan amount of XXXXXX  exceeds max loan amount of $3,000,000 at 75% LTV.

Reserves are 40.54 months, 28.54 month> program requirement of 12 months. DTI is 34.652%, 15.348%< program maximum of 50%. Custom built Contemporary/Modern designed home located within XXXXXX Self-employed for the past 19 years as XXXXXX Excellent credit history with multiple accounts paid as agreed and no public records 6 Active and 7 closed mortgages paid as agreed since earliest inception 10/2004 Credit score 766, 46> program requirement of 720

Aggregator Aggregator Aggregator Aggregator Aggregator Aggregator Aggregator

Reviewer Comment (2019-07-31): Client elects to waive the exception with verified compensating factors Buyer Comment (2019-07-30): Please see attached revised exception Reviewer Comment (2019-07-24): DTI is 31.339%, 18.661% < program maximum of 50% is not a valid comp factor. Calculated DTI is 34.65161%. Reserves are 82 months, 70 months > program requirement of 12 months is not a valid comp factor. Verified reserves of 40.54 months. Provide an updated Exception Request with valid comp factors. Buyer Comment (2019-07-23): Approved credit exception uploaded for review.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902042

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902042

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $2,000.00 exceeds tolerance of $1,200.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902042

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Missing the Audited YTD P&L, most recent business tax transcripts and signed 1120's.

Reviewer Comment (2019-08-09): Signed XX 1120S return and signed XX 1040 personal return provided. Buyer Comment (2019-08-08): See attached signed tax returns Reviewer Comment (2019-08-01): Tax returns are not signed and dated. Exception remains. Buyer Comment (2019-08-01): Audit P & L and Transcripts are not required.  Tax returns are in the file. Reviewer Comment (2019-07-31): Unable to waive exception as tax transcript is a required ATR document for S-Corp income. Buyer Comment (2019-07-30): See attached

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902042

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Missing the Audited YTD P&L, most recent business tax transcripts and signed 1120's.

Reviewer Comment (2019-08-09): Signed XX 1120S return and signed XX 1040 personal return provided. Buyer Comment (2019-08-08): See attached signed returns Reviewer Comment (2019-08-01): Tax returns are not signed and dated. Exception remains. Buyer Comment (2019-08-01): Audit P & L and Transcripts are not required.  Tax returns are in the file. Reviewer Comment (2019-07-31): Unable to waive exception as tax transcript is a required ATR document for S-Corp income. Buyer Comment (2019-07-30): See attached

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902042

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Missing the Audited YTD P&L, most recent business tax transcripts and signed 1120's.

Reviewer Comment (2019-08-09): Signed XX 1120S return and signed XX 1040 personal return provided.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902042

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/9/XX 12:00:00 AM was received.

Revised LE dated XXXX19 was acknowledged as being received by the borrower the same day as the initial CD dated XXXX19.

Buyer Comment (2019-07-23): XXXXXX has elected to waive this exception.

07/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902043

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.66060% or Final Disclosure APR of 7.65400% is in excess of allowable threshold of APOR 3.87% + 1.5%, or 5.37000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-07-26): Appraisal provided to borrower XXXXXX

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902043

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Engine Required from Mavent or ComplianceEase. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-07-26): Compliance report provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902043

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-26): Appraisal provided to borrower XXXXXX

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902043

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-07-26): Appraisal provided to borrower XXXXXX

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902043

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $600.00 exceeds tolerance of $475.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902043

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Divorce Decree / Child Support not provided

Final 1003 shows a monthly alimony/child support/separate maintenance payment of $xxxx. Missing documentation to support.

Reviewer Comment (2019-07-30): Divorce Decree / Child Support not required. Reviewer Comment (2019-07-26): Initial 1003 e-signed XXXXXX does not reflect child support in the liability section and the answer to the Declaration quest G is no. The final 1003 dated XXXXXX shows support in the liability section and the Declaration question G is no. Provide a revised 1003 signed by the borrower. Buyer Comment (2019-07-25): borrower doesn't owe any child support and that the 1003 was in error and final 1003 signed does not reflect child support

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Exception to Policy - Lenders Exception Allow income calculation based on 8 months business bank statements vs program requirement of 12 months of statements reviewed

VOR reflects 0x30 since inception XXXXXX. Credit history reflects paid as agreed except for an isolated revolving 30-day late in XXXXX. No public records Borrower has been self-employed for the past 2 years as a 34.80% owner XXXXXX DTI of 42.06481% is .93519% less than program max of 43% 764 representative FICO score > 680 guideline minimum - 84 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-24): Client has elected to waive this exception based on compensating factors.

07/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

List of Homeownership Counseling Organizations not provided to the borrower

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $56,646.41 and disclosure timing violations.

Esign Consent disclosure not in file. Disclosures sent electronically may result ins a fee tolerance and disclosure timing violation

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): EConsent provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Your Home Loan Toolkit disclosure not provided to the borrower

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided to borrower at least 3 business days before closing

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): Initial CD provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Loan Estimate not delivered to the Borrower within 3 business days of application. The initial Loan Estimate was electronically provided without the borrower's consent.

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): E-Consent provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

List of service providers not provided to the borrower

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): SSPL provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

ARM Disclosure not provided to the borrower

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): Early ARM disclosure provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902044

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

CHARM Booklet not provided to the borrower

Reviewer Comment (2019-07-26): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): Disclosure Tracking provided

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902045

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-07-30): AMC received the completed and signed attestation dated 7/XX19. Buyer Comment (2019-07-30): Brwr ATR Attestation provided

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902045

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided to the Borrower three business days prior to closing.

Reviewer Comment (2019-07-26): AMC received XX25 CD received the same day. Exception Cleared. Buyer Comment (2019-07-25): See trailing document

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902046

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-24): XXXXXX has elected to waive

07/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902046

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Borrower does not have the minimum active tradelines per guidelines.

Borrower has 1 trade line only that is active and rated 29 months vs program requirement of at least 3 trade lines rated at minimum 12 months with 2 active within 12 months of the credit date.

Borrower has been employed for the past 2.5 years as a XXXXXX Minimal credit user with 1 active account paid as agreed. No public records. 750 representative FICO score > 640 guideline minimum - 110 points above guideline minimum LTV is 69.93%, 15.07% < program maximum of 85% with 50% DTI

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-24): Client has elected to waive this exception based on compensating factors.

07/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902047

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902047

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Final CD reflected a finance charge that was $550 under disclosed. Missing the compliance report to verify fees not disclosed.

Reviewer Comment (2019-07-30): SitusAMC received required documents, exception is cleared.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902047

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Sellers CD not provided

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902047

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing evidence borrower was provided a copy of the list of service providers at time of application.

Reviewer Comment (2019-07-30): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-07-29): SSPL's provided

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902047

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Missing borrower signed Ability to Repay Attestation as required per guidelines.

Reviewer Comment (2019-07-30): AMC received the borrower attestation signed and completed. Buyer Comment (2019-07-29): Borrower ATR Attestation provided

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902047

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing the ComplianceEase or Mavent as required by the guides.

Reviewer Comment (2019-08-12): Compliance report provided Buyer Comment (2019-08-09): Compliance report provided

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902047

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

No VCC was located in the loan file that would account for the fee increase.

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902047

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $310.00 exceeds tolerance of $135.00 plus 10% or $148.50.  Insufficient or no cure was provided to the borrower.

No VCC was located in the loan file that would account for the fee increase.

Reviewer Comment (2019-08-12): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided.  Confirmed total recording fee was reduced to $163 on Post Close CD and Final Settlement Statement and cure of $14.50 provided tot the borrower. Buyer Comment (2019-08-09): See cure documents provided

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902048

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Secondary Financing monthly payment for xxxx, FL was not provided.

Reviewer Comment (2019-07-26): Credit report discloses a HELOC. Buyer Comment (2019-07-25): HELOC w/ XXXXXXreporting on credit as 2nd lien to XXXXXX- please clear

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Reviewer Comment (2019-07-25): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): E-consent provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $41,648.64 and disclosure timing violations.

Initial LE sent electronically and e-sign consent was not provided resulting in a fee tolerance violation.

Reviewer Comment (2019-07-25): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): E-consent provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD disclosed a change in Total Closing Costs, however, did not disclose the amount by which the change exceeded the legal limit.

Buyer Comment (2019-07-25): XXXXXX has elected to waive this exception.

07/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $20,583.09 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE sent electronically and e-sign consent was not provided resulting in a fee tolerance violation.

Reviewer Comment (2019-07-25): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): Valid change form provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $650.00.  Insufficient or no cure was provided to the borrower.

Initial LE sent electronically and e-sign consent was not provided resulting in a fee tolerance violation.

Reviewer Comment (2019-07-25): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): Valid change form provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE sent electronically and e-sign consent was not provided resulting in a fee tolerance violation.

Reviewer Comment (2019-07-25): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): Valid change form provided

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902048

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Survey Fee.  Fee Amount of $300.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No COC or cure provided for the addition of the Survey fee.

Reviewer Comment (2019-07-25): AMC received required documents, exception is cleared. Buyer Comment (2019-07-25): See trailing documents

07/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902049

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Fraud Report not provided

Reviewer Comment (2019-08-01): Fraud Report provided Buyer Comment (2019-07-31): Fraud report provided

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

-

Fraud Report is missing.

Reviewer Comment (2019-08-01): Fraud Report provided Buyer Comment (2019-07-31): Fraud provided

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Missing LO Compensation Disclosure

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing a copy of the Right to Receive a Copy of Appraisal Disclosure

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.02400% or Final Disclosure APR of 7.05300% is in excess of allowable threshold of APOR 4.26% + 1.5%, or 5.76000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-08-01): Initial documentation provided. Buyer Comment (2019-07-31): See trailing documents

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing a copy of the Right to Receive a Copy of Appraisal Disclosure

Reviewer Comment (2019-08-01): Initial documentation provided. Buyer Comment (2019-07-31): Disclosure provided

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing LO Compensation Disclosure

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Missing Disclosure

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

List of Homeownership Counseling Organizations is missing.

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Contact Information - Broker

TILA-RESPA Integrated Disclosure - Contact Information: Final Closing Disclosure provided on XXXXXX did not disclose the required  Broker  Contact Information (Broker Name, Broker NMLS ID, Contact Name, Contact NMLS ID).

Final disclosure contains no broker contact information

Reviewer Comment (2019-08-02): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-08-01): Re-uploaded PCCD dated 8/1/XX Reviewer Comment (2019-08-01): AMC received LEs, CD, and COCs. A corrected CD and LOE is required to cure. Buyer Comment (2019-08-01): See trailing documents

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing Evidence that the Home Loan Toolkit Booklet was provided.

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

The only CD provided was the one that was issued the same date as closing.

Reviewer Comment (2019-08-01): AMC received LEs, CD, and COCs. Exception Cleared. Buyer Comment (2019-07-31): Initial CD provided

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $7,151.81 may be required.

No LE's were located in the loan file.

Reviewer Comment (2019-08-01): AMC received LEs, CD, and COCs. Exception Cleared. Buyer Comment (2019-07-31): Econsent and SSPL also provided Buyer Comment (2019-07-31): LE's & CoC's provided

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Missing Seller's CD

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Missing a copy of the ARM Disclosure

Reviewer Comment (2019-08-01): Initial documentation provided. Buyer Comment (2019-07-31): ARM disclosure provided

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Missing evidence that the borrower was provided a copy of the CHARM Booklet.

Reviewer Comment (2019-08-01): Initial documentation provided. Buyer Comment (2019-07-31): Evidence CHARM provided to client uploaded

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-01): Approval provided Buyer Comment (2019-07-31): Approval provided

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $90.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

AMC received LEs, CD, and COCs. The XX09 COC does not indicate a valid change of circumstance to add the appraisal desk fee. Please provide additional details regarding what changed that required the fee or please provide a corrected CD, LOE, and refund check to cure.

Reviewer Comment (2019-08-02): COC provided - Desk review requested

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902049

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

AMC received LEs, CD, and COCs. Please see appraisal desk review fee exception.

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Reviewer Comment (2019-07-30): SitusAMC received required documents, exception is cleared.

07/30/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $695.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $695.00.  Insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-07-30): SitusAMC received required documents, exception is cleared.

07/30/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

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

C

A

A

A

C

A

A

A

Non QM

Non QM

Yes

207902050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $14,077.00 and disclosure timing violations.

File contains evidence that the borrower received electronic disclosures, missing documentation of consent

Reviewer Comment (2019-07-30): SitusAMC received required documents, exception is cleared.

07/30/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Reviewer Comment (2019-07-30): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-07-29): Please see uploaded COCs

07/30/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

A

A

A

C

A

A

A

Non QM

Non QM

Yes

207902050

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Extension Fee.  Fee Amount of $3,000.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Extension Fee. Fee Amount of $3,000.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-07-30): SitusAMC received required documents, exception is cleared.

07/30/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

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

C

A

A

A

C

A

A

A

Non QM

Non QM

Yes

207902051

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Coverage shortage of $282,559 does not meet loan amount of $xxxx

Reviewer Comment (2019-07-30): AMC received the replacement cost estimator at $247,997. Buyer Comment (2019-07-30): See attached

07/30/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

207902051

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Reviewer Comment (2019-07-29): REO Documents provided. Buyer Comment (2019-07-29): See attached

07/29/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

207902051

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow funds for closing in the amount of $300,000 from XXXXXX  vs program requirement of a gift letter with gift funds.

Borrower has been self-employed for the past 7 years as XXXXXX New construction project Mortgage history with 2 active mortgages and 1 HELOC paid as agreed since earliest inception XXXXXX. 8 concurrent purchase transactions for total of 9 financed properties and 1 lot loan. No public records. 167.41 months reserves > 19 months guideline minimum 707 representative FICO score > 640 guideline minimum - 67 points above guideline minimum

Originator Originator Originator Originator Originator

Reviewer Comment (2019-08-28): Client has elected to waive this exception based on the compensating factors.

08/28/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

207902052

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Reviewer Comment (2019-07-31): Replacement cost estimator provided Buyer Comment (2019-07-30): See attached RCE Reviewer Comment (2019-07-29): Per guide, coverage amount is the ls the lesser of the full replacement cost, which none was provided and loan amount, but not less than 80% of the replacement cost. Since the replacement cost was not provided, the appraised value is used of $xxxx x 80% = $xxxx (short $14,320.00) Buyer Comment (2019-07-26): Coverage amount matches the loan amount.  Please explain why it is insufficient.

07/31/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

B

B

A

A

N/A

N/A

No

207902052

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Asset qualifications not met per guidelines.

Total assets: ___;  Reserves: ___

Allow funds for closing costs in the amount of $300,000 from XXXXXX  vs. program requirement of gift letter with gift funds.  Approved Lender Exception in file.

No public records.  Mortgage history with 2 active mortgages and 1 HELOC paid as agreed since earliest inception XXXXXX Reserves are 247.22 months, 9.44 months > program requirement of 11 months 3 months +1 month for each additional financed investment property) Borrower has been self-employment for the past 7 years as XXXXXX Credit score is 707, 67 points > program requirement of 640,

Originator Originator Originator Originator

Reviewer Comment (2019-07-25): Client has elected to waive this exception based on compensating factors.

07/25/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

B

B

A

A

N/A

N/A

No

207902052

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Missing proof of Principle, Interest, Taxes, and Insurance for REO properties.

Reviewer Comment (2019-08-09): Denial letters provided for XXXXXX Buyer Comment (2019-08-07): Please see attached evidence that XXXXXX Is sold and find attached revised 1003, 1008 and ctc approval without the Lot xxx property. Buyer Comment (2019-08-07): Please see attached evidence of the property associated with Loan # 's on the adverse action letters. Reviewer Comment (2019-08-05): Documentation showing that there was an application that was approved and not accepted by the borrower. Unable to determine property address. Also, need monthly payment for XXXXXX, plus evidence of taxes for XXXXXX. Subject to DTI recalculation. Buyer Comment (2019-08-02): See attached Reviewer Comment (2019-08-02): Provided disposition for property XXXXXX. Conflicting information on 1003's provided. Buyer Comment (2019-08-01): I will send adverse action letters for XXXXXX ASAP. Buyer Comment (2019-08-01): See attached re: XXXXX Reviewer Comment (2019-07-31): Revised 1003, 1008 and loan Approval provided removing the properties at XXXXX. File contains payments coupons for XXXXX (page 1055/D0296 and 1057/D0297) in the borrower's name. Provide documentation that the properties are not owned by the borrower. Also need documentation for XXXXX Buyer Comment (2019-07-30): Please disregard the First Payment letters for the properties at XXXXXX.  See attached revised 1003 and 1008 and ctc approval.  The borrower did not purXXXXXX these homes. Reviewer Comment (2019-07-30): Documentation not provided in trailing docs for XXXXXX. Please provide documentation that pertains only to these properties. Buyer Comment (2019-07-26): see attached

08/09/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

B

B

A

A

N/A

N/A

No

207902052

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Missing

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to consumer.

Buyer Comment (2019-07-26): XXXXXX has elected to waive this exception.

07/26/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

B

B

A

A

N/A

N/A

No

207902055

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation  disclosure not provided. Unable to determine if compensation was based on a term of the transaction

Buyer Comment (2019-07-26): XXXXXX has elected to waive this exception.

07/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902055

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $460.00 exceeds tolerance of $450.00.  Sufficient or excess cure was provided to the borrower at Closing.

Appraisal Fee amount of $460.00 exceeds tolerance of $450.00. Sufficient cure was provided to the borrower

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207902055

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $459.65 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower at Closing.

Initial LE reflected a credit report fee of $50 yet the final CD shows $459.65. Lender provided sufficient cure to borrower.

07/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207902056

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902056

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902056

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902056

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Appraisal reflects an annual expense for HOA of $2,035.00 or $169.58 per month, final disclosure reflects a monthly expense of $16.95.

Reviewer Comment (2019-08-26): AMC received PCCD correcting non escrowed property costs and LOE. Exception Cured. Buyer Comment (2019-08-23): PCCD & LOE provided

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902056

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902056

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $650.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $650.00 exceeds tolerance of $0.00.  Missing proof of valid change, insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-08-15): Survey fee shopped for - confirmed provider not on SSPL Buyer Comment (2019-08-14): Survey was borrower elected and shopped for - please clear.

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902056

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX CHL Complaint Agency Disclosure Timing Test

XXXXXX 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.

Reviewer Comment (2019-07-30): AMC received the SC disclosure dated 6/XX19. Buyer Comment (2019-07-30): SC disclosure provided

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902056

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $2,858.00 and disclosure timing violations.

File contains evidence that the borrower received electronic disclosures, missing documentation of consent

Reviewer Comment (2019-07-30): AMC received the E-consent dated 6/XX19. Buyer Comment (2019-07-30): Econsent provided

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902056

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

File contains evidence that the borrower received electronic disclosures, missing documentation of consent

Reviewer Comment (2019-07-30): AMC received the E-consent dated 6/XX19. Buyer Comment (2019-07-30): Econsent provided

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902057

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

The hazard insurance policy effective date is after the Transaction disbursement date of XXXXXX.

Reviewer Comment (2019-07-30): AMC received the revised HOI policy dated 7/XX19-7/XX20. Buyer Comment (2019-07-30): Expiration date on revised policy XXXX2020 - please clear Reviewer Comment (2019-07-30): Updated HOI policy has an expiration date of XXXXXX. Per guide, policy must be effective for at least 60 days after date of loan. Exception remains. Buyer Comment (2019-07-30): Revised EOI provided

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902057

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

FACTA Disclosure Missing

FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.

Borrower did not receive the FACTA credit score disclosure

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902057

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

List of Homeownership Counseling Organizations not provided to the borrower

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902057

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

Disclosure reflects TIP of 170.452% but calculated TIP is 162.377% which is outside of .003% tolerance. Used Index Value = 2.2978% per Compliance document in file.

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902057

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

ARM loan disclosure not provided to borrower at least 3 days of application

Reviewer Comment (2019-07-30): Initial ARM disclosure provided Buyer Comment (2019-07-30): ARM disclosure provided

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902058

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-08-02): AMC received the completed and signed ATR attestation. Buyer Comment (2019-08-02): ATR Attestation provided

08/02/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902058

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

Missing copy of most recent asset statement (1 of 2 monthly statement provided).

Reviewer Comment (2019-07-30): Additional month statement provided for Employee Stock Ownership Plans. Buyer Comment (2019-07-29): Asset Statements provided - not used for closing cost, only reserves.

07/30/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902058

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902058

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

CD reflects $28.00 xxxx per the appraisal HOA is 470.00 annually or 39.17 a month.

Reviewer Comment (2019-08-05): AMC received PCCD correcting non escrowed property costs and LOE. Exception Cured. Buyer Comment (2019-08-02): PCCD and LOE provided

08/05/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902058

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

List of Service Providers is missing from file.

Reviewer Comment (2019-08-05): AMC received SSPL. Exception Cleared. Buyer Comment (2019-08-02): SSPL provided

08/05/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902058

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow attorney letter confirming both parties are in the process of filing for a Petition of Dissolution vs. program requirement of providing a legal Separation Agreement or Divorce Decree

28.11307% DTI on this Alt documentation loan < 50% guideline max - 21.88693% below program guideline maximum Perfect mortgage history with 3 active mortgage paid as agreed since inception XXXXXX. Perfect credit history since inception of earliest account opened XXXXXX. No public records Reserves are 110% of the loan amount plus  PITI reserves, $2,226,813.87 > program requirement of 110% plus 5 months (3 month plus 2  investments) Credit score is 789, 109 points > program requirement of 680 Per Attorney letter, both parties have agreed to waive maintenance, no child support, XXXXXX to be awarded to spouse, borrower to retain $2.2 million in assets and signed by both parties.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-27): Client has elected to waive this exception based on compensating factors.

07/27/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902058

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Loan is an ARM with verbiage allowing assumption. CD indicated not assumable

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902058

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Please provide asset for use as closing funds as XXXXXX not used to close only for income and reserves.

Reviewer Comment (2019-08-05): Corrected usability of assets for funds to close. Reviewer Comment (2019-08-05): Funds used for closing must be liquid. Asset statement provided are retirement account and can not be used for closing. Buyer Comment (2019-08-05): See UW explanation provided - depletion income reduced by amount due for closing.

08/05/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

The file contained documentation verifying the borrower was provided with a copy of the appraisal on XXXXXX, which is prior to the appraisal report date of XXXXXX. Evidence borrower received a copy of the revised appraisal was not provided.

Reviewer Comment (2019-08-02): Effective date is XXXXXX

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

The file contained documentation verifying the borrower was provided with a copy of the appraisal on XXXXXX, which is prior to the appraisal report date of XXXXXX. Evidence borrower received a copy of the revised appraisal was not provided.

Reviewer Comment (2019-08-02): Effective date is XX16XX

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 8.37080% or Final Disclosure APR of 8.40300% is in excess of allowable threshold of Prime Mortgage Market Rate 3.82000 + 1.75%, or 5.57000%.  Non-Compliant SubPrime Loan.

Compliant XXXXXX Subprime Loan.

Buyer Comment (2019-08-05): waive Reviewer Comment (2019-08-05): Timing exception cleared and XXXXXX Subprime exception downgraded to EV2 with comment that loan is compliant.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Services Sales Tax.  Fee Amount of $61.67 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2019-08-07): SSPL provided borrower shopped for fees Reviewer Comment (2019-08-05): AMC reviewed the exception. Please provide the SSPL as it is not located in file. Buyer Comment (2019-08-02): the cure - we already refunded $5 (via tolerance cure).  The remainder you are requesting is not founded as the fee is payable to someone not on our SSPL so therefore we are not held to tolerance.  It's just a sales tax (NOT mortgage tax) - nothing more.

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Partial Payments

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Partial Payments.

Page 4 of final CD did not disclose whether the loan allows for Partial Payments.

Reviewer Comment (2019-08-07): AMC received the corrected PCCD and LOE. Reviewer Comment (2019-08-07): Corrected Closing Disclosure received by AMC.  Letter of explanation to borrower still required to cure.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure of $5.00 was reflected, which is insufficient to cure Title - Services Sales Tax of $61.67.

Buyer Comment (2019-08-05): waive

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence disclosure was provided to the borrower.

Reviewer Comment (2019-08-02): Disclosure provided.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing evidence disclosure was provided to the borrower.

Reviewer Comment (2019-08-02): Disclosure provided.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Missing documentation to support clearance of earnest money deposit of $1,000 in order to meet reserve requirement.

Reviewer Comment (2019-08-02): Reserve requirement met.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Engine Required from Mavent or ComplianceEase. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-08-02): Mavent provided.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902059

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower within three days of application.

Loan file only contains disclosure was provided at closing, XXXXXX.

Reviewer Comment (2019-08-02): Counseling Disclosure provided on 6/13, within three days of loan becoming a XXXXXX Subprime.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Representative FICO score of ___ is less than Guideline representative FICO score of ___.

Lender approved exception to allow FICO of 677 vs program requirement of 680

Borrower has been self-employed for the past 2 years as XXXXXX and has 15 years in the industry. Minimal credit user with all accounts paid as agreed. No collection or public records.

Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-29): Client has elected to waive this exception based on compensating factors.

07/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902059

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Service Provider - Compliant

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

Actual list not in file.

Reviewer Comment (2019-08-07): SSPL provided borrower shopped for fees Buyer Comment (2019-08-06): uploaded SSPL

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902060

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Buyer Comment (2019-07-30): waive

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902060

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-30): waive

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902060

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Issue and Received Date >  Closing Disclosure Issue and Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on or after the date the Closing Disclosure was provided. (The Revised Loan Estimate was received on or after the Closing Disclosure.)

Loan Estimate not provided to borrower at least four days prior to closing.

Reviewer Comment (2019-07-31): Revised LE issued XXXXXX Buyer Comment (2019-07-30): LE rcvd date is X/XX and consummation date is 7/17

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902060

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXXX not received by borrower at least four (4) business days prior to closing.

Loan Estimate not provided to borrower at least four days prior to closing.

Reviewer Comment (2019-07-31): Revised LE issued XXXXXX Buyer Comment (2019-07-30): uploaded disclosure tracking. initial CD sent X/XX

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902061

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-08-13): AMC received the ATR attestation completed signed and dated 6/XX19. Buyer Comment (2019-08-13): ATR Attestation provided

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902061

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902061

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $60.00 exceeds tolerance of $40.00 plus 10% or $44.00.  Sufficient or excess cure was provided to the borrower at Closing.

Ten percent fee tolerance exceeded by $60.00.

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207902061

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit is missing from file.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902061

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

13.56489% DTI on this Alt documentation loan < 50% guideline max - 36.43511% below program guideline maximum Tradelines paid as agreed since foreclosure XXXXXX Borrower has been XXXXXX for the past 3 years. FICO of 673, 33 points > program requirements of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-29): Client has elected to waive this exception based on compensating factors.

07/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902062

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902062

XXXXXX

XXXXXX

Property

Property - Appraisal

General Appraisal Requirements

Valuation Error: Appraiser and/or Supervisory appraiser are not licensed or certified in the appraiser national registry.

-

Reviewer Comment (2019-07-31): Last was was misspelled. Appraiser is licensed and in national registry. Buyer Comment (2019-07-30): Drive Report for review See Appraiser Profile page 25

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902062

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Reviewer Comment (2019-07-31): Mtg statement provided. Buyer Comment (2019-07-30): Drive Report for review See Appraiser Profile page 25, CD Tracking Loan closed X/XX, XXXX Mtg statement

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902062

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Initial CD issued XXXX19 was issued less than three business days prior to closing

Reviewer Comment (2019-07-31): AMC received disclosure tracking indicating the XX17 CD was received the same day. Exception Cleared. Buyer Comment (2019-07-30): Drive Report for review See Appraiser Profile page 25, CD Tracking Loan closed X/XX

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

C

A

Non QM

Non QM

No

207902063

XXXXXX

XXXXXX

Credit

TRID

Document Error

Equity of Sold Property was reflected on Closing Disclosure, however missing evidence of sold property.

The borrower's existing primary residence located at: XXXXXX; was listed on the final application as "Pending Sale" with net proceeds of $75,000 used to support sufficient funds to close. The following mortgage was also excluded from the borrower's debt analysis in lieu of the pending sale: XXXXXX with a monthly payment of $2,142 and a balance of $249,379. Missing evidence that this property was sold and that the borrower netted at least $75,000. Without this verification the borrower has insufficient funds for closing & reserves and the existing housing payment would have to be added back into the debt analysis (DTI would increase from 37% to 48.57%).

Reviewer Comment (2019-08-01): Seller CD for XXXXX provided for assets. Buyer Comment (2019-07-31): Seller CD for XXXXXX

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902063

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Missing a copy of the fully executed HUD and/or wire confirmation to confirm the borrower's receipt of at least $75,000 from the sale of the borrower's existing primary residence.

Reviewer Comment (2019-08-01): Seller CD for XXXXX provided for assets.

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902063

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Missing Final HUD/CD from sale of home reflecting net proceeds of at least $75,000.

Reviewer Comment (2019-08-01): Seller CD for XXXXX provided for assets.

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902063

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

LO Compensation Disclosure Missing

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902063

XXXXXX

XXXXXX

Credit

Missing Document

General

One or more of your documents was not signed and dated by the borrower(s).

Final CD issued XXXXXX was not signed and dated by the borrower.

Reviewer Comment (2019-08-01): Seller CD for XXXXX provided for assets. Buyer Comment (2019-07-31): Seller CD for XXXXXX,Signed CD for subject

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902065

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-07-30): waive

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

B

B

D

B

A

A

Non QM

Non QM

No

207902065

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-30): waive

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

B

B

D

B

A

A

Non QM

Non QM

No

207902065

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

Colorado Home Loan (Tangible Net Benefit Disclosure Not Provided)

XXXXXX Home Loan (HB1322):  Loan file does not contain a Tangible Net Benefit Disclosure (or similar document).

Buyer Comment (2019-07-30): waive

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

B

B

D

B

A

A

Non QM

Non QM

No

207902065

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

The borrower is self-employed.  Guidelines require either a tax professional letter or regulatory agency verifying at least 2 years of self-employment along with either a phone listing and/or business address using directory assistance or internet search to be in file.

Borrower's business, XXXXXX, came into existence in September XX (22 months) vs. program requirement that the borrower must have been continually self employed for 2 years.  Approved Lender Exception in file.

Four mortgages reflects 0x30 since inception XXXXXX.  One closed mortgage reflects paid as agreed.   Credit history reflects paid as agreed.  Credit history reflects paid as agreed since isolated 30-day waiting revolving late in XXXXXX.  No public records. Borrower has been in the same line of business for the past 5 years. DTI  is 44%, 6% < program max of 50% 7.94 months reserves, 1.94 months > program requirement of 6 months

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-29): Client has elected to waive this exception based on the compensating factors.

07/29/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

B

B

D

B

A

A

Non QM

Non QM

No

207902065

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Closing / Title

Missing Final HUD-1

Missing final HUD/Closing Disclosure for 3 other REO properties refinanced concurrently (loan #'s xxxx) confirming other debts paid in full.

Reviewer Comment (2019-07-31): Final HUDs for REOs provided. Payoffs confirmed.

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

B

B

D

B

A

A

Non QM

Non QM

No

207902066

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-07-29): XXXXXX has elected to waive this exception.

07/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902066

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Guideline Requirement: Documented income duration  did not support the minimum guideline required duration.

Alimony ending in 30 months vs. guideline requiring continuance of 36 months.  Approved Lender Exception in file.

No public records. Borrower has been in the same line of work for the past 25 years as a XXXXXX. Borrower earns income as a XXXXXX DTI is 35.83938%, 7.16062% < program max of 43% 32.86 months of reserves, 26.86 months > program requirement of 6 months Credit score is 697,  37 points > program requirement of 660. LTV is 80%, 10% < program max of 90%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-29): Client has elected to waive this exception based on compensating factors.

07/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902067

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-31): waive

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902067

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXX exceeds tolerance of $3,600.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/29/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902067

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charges under disclosed by $300.

Reviewer Comment (2019-08-13): Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission has been provided.  Rescission expired on 8/8/19. Buyer Comment (2019-08-12): rescission expired. please clear Reviewer Comment (2019-08-05): AMC received RTC to be delivered XX05. Rescission will end XX08 if delivered today. Exception may be cured XX09. Reviewer Comment (2019-08-01): PCCD, LOE, Copy of Check and UPS tracking label have been received.  Rescission must be reopened.  Please provide Right To Cancel and Proof of Delivery to Borrower to cure.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902069

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-02): AMC received the final title with coverage of $300,000. Buyer Comment (2019-08-02): Uploaded For Review-Title Policy. Reviewer Comment (2019-08-01): Incorrectly waived. Buyer Comment (2019-08-01): XXXXXX has elected to waive this exception. Buyer Comment (2019-08-01): Uploaded For Review- Final Title Policy

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

B

A

B

B

A

A

Non QM

Non QM

No

207902069

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Reviewer Comment (2019-08-02): AMC received the final title with coverage of $300,000.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

B

A

B

B

A

A

Non QM

Non QM

No

207902069

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-01): XXXXXX has elected to waive this exception

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

B

A

B

B

A

A

Non QM

Non QM

No

207902070

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Missing Document: Asset Documentation not provided

Missing transaction history for XXXXXX from XXXXXX through XXXXXX

Reviewer Comment (2019-08-09): Asset XXXXXXnot used in closing/reserves removed from assets. Reviewer Comment (2019-08-08): A Printout dated XXXXXX for XXXXXX was provided (page 5XXD0013) that shows the transactions from XXXXXX to XXXXXX. Requesting statement/transaction history  from XXXXXX to XXXXXX. Buyer Comment (2019-08-07): This account was utilized for the income calculation of the loan, is not to be utilized for cash to close/reserves.  The documentation provided is sufficient per guidelines for this, please review and advise. Reviewer Comment (2019-08-06): Print out in file for statement is dated 6/XXXX and only contains history for 6/14-6/11. Missing history from 5/XX19-6/XX19. Reviewer Comment (2019-08-06): Bank statement sent is for XX and we need history from XXXXXX - XXXXXX. Buyer Comment (2019-08-05): Uploaded again-BOA statements Reviewer Comment (2019-08-02): Nothing uploaded to trailing docs in file for period from XXXXXX through XXXXXX. Buyer Comment (2019-08-01): Uploaded For Review-BOA statement

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902070

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

The effective date of the hazard insurance declaration page provided reflects XXXXXX, however the loan disbursed on XXXXXX. Therefore the subject property was without adequate HOI coverage for 3 days.

Reviewer Comment (2019-08-01): AMC receive with HOI policy with effective dates as 6/XX19-6/XX20. Buyer Comment (2019-08-01): Uploaded For Review-Ins. with correct effective date.

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902070

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Policy amount was not referenced on the preliminary title report provided.

Reviewer Comment (2019-08-05): Final title Policy provided. Buyer Comment (2019-08-05): Uploaded For Review-Final title Policy

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902070

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Final Title Policy was not provided

Reviewer Comment (2019-08-05): Final title Policy provided.

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902070

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___

Missing the CPA Letter,d third party verification of business / Listing for ownership %.

Reviewer Comment (2019-08-02): CPA Letter provided. Buyer Comment (2019-08-01): Uploaded For Review-CPA Letter

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902070

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-08-01): XXXXXX has elected to waive this exception.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902070

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Loan is a fixed rate, not assumable

Buyer Comment (2019-08-01): XXXXXX has elected to waive this exception.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207902070

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-08-01): XXXXXX has elected to waive this exception.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902070

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on XXXXXX disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table.

Final CD contains payoff of TD Auto Finance.  Most recent credit report in file shows TD Auto paid off prior to closing.

Buyer Comment (2019-08-01): XXXXXX has elected to waive this exception.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207902071

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Reviewer Comment (2019-07-31): AMC received the homeownership counseling disclosure dated 6/XX19. Buyer Comment (2019-07-31): Counseling List provided Reviewer Comment (2019-07-31): Disclosure Tracking Details shows document was sent to the borrower on XXXXXX. Missing a copy of the List of Counseling Organizations to verify compliance. Must reflect a minimum of 10 organizations. Buyer Comment (2019-07-30): See page 3 of Disclosure Tracking - Disclosure sent 6/XXXX

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902071

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

Evidence receipt of servicing disclosure not provided.

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902071

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered or placed in the mail to Borrower(s) within three (3) business days of application.

Evidence receipt of LE within 3 business days of application not provided.

Reviewer Comment (2019-07-31): AMC received the LE dated 6/XX19, electronically received on 6/XX19. Buyer Comment (2019-07-31): Initial LE X.XX.XX provided Reviewer Comment (2019-07-31): The Only LE in the loan file was issued on XXXXXX.  Application date was XXXXXX.  The disclosure summary provided by the lender confirms an LE was issued and received by the borrower on XXXXXX.  Please provide the XXXXXX LE it is currently missing from the loan file. Buyer Comment (2019-07-30): See disclosure tracking and Econsent provided

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902071

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Seven Day Waiting Period

TILA-RESPA Integrated Disclosure: Loan Estimate was not delivered or placed in the mail to the borrower at least seven (7) business days prior to closing.

Evidence receipt of LE within 3 business days of application not provided.

Reviewer Comment (2019-07-31): AMC received the LE dated 6/XX19, electronically received on 6/XX19. Buyer Comment (2019-07-31): See trailing documents Reviewer Comment (2019-07-31): The Only LE in the loan file was issued on XXXXXX.  Application date was XXXXXX.  The disclosure summary provided by the lender confirms an LE was issued and received by the borrower on XXXXXX.  Please provide the XXXXXX LE it is currently missing from the loan file. Buyer Comment (2019-07-30): Initial LE dated XXXXXX / received same day electronically

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902071

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Evidence list of service providers received not in file.

Reviewer Comment (2019-07-31): Settlement Service Provider list issued XXXXXX. Buyer Comment (2019-07-30): SSPL uploaded

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902071

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

ARM disclosure not provided.

Reviewer Comment (2019-07-31): AMC received the ARM disclosure dated 6/XX19. Buyer Comment (2019-07-31): ARM disclosure provided Reviewer Comment (2019-07-31): Disclosure Tracking Details shows document was sent to the borrower on XXXXXX. Missing copy of ARM Disclosure to verify compliance. ARM disclosure must provide details for the 5/1 ARM program. Buyer Comment (2019-07-30): See disclosure tracking provided - ARM disclosure provided 6/25 - see page 3 of Disclosure Tracking provided

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902072

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-30): XXXXXX has elected to waive this exception.

07/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902075

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Hazard Insurance Policy Effective Date XXXXXX, Transaction Date:  XXXXXX

CDAIR in final inspection date of 08/09/2019, with no damage observed. 11.69 months reserves > 3 months guideline minimum by 8.69 months 25.163% DTI on this bank statement documentation loan < 43% guideline max - 17.837% below program guideline maximum 780 representative FICO score > 680 guideline minimum - 100 points above guideline minimum

Originator Originator Originator Originator

Reviewer Comment (2019-09-03): Client elects to waive the exception with verified compensation factors. Buyer Comment (2019-08-30): Please see approved exception and No Claims Letter

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902075

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-08): XXXXXX has elected to waive this exception

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902075

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Revised loan estimate dated XXXXXX was electronically received prior to the loan estimate dated XXXXXX

Reviewer Comment (2019-08-01): Evidence of receipt provided. Buyer Comment (2019-08-01): Please see LE TRACKING, 7-17 LE TRACKING reflecting 7-17 LE was viewed at 3:29pm while 7-15 LE was viewed at 1:30pm

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902075

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXXX not received by borrower at least four (4) business days prior to closing.

Revised loan estimate dated XXXXXX was not received by the borrower at least 4 business days prior to closing

Reviewer Comment (2019-08-01): Evidence of receipt provided. Buyer Comment (2019-08-01): Please see LE TRACKING

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902076

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Reinspection Fee.  Fee Amount of $175.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

07/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

D

A

D

A

A

A

A

A

Non QM

Non QM

Yes

207902076

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Purchase Agreement / Sales Contract not provided

Purchase agreement in file shows sales price is xxxxx however final seller's CD shows it isxxxxx. Missing sales contract addendum verifying final sales price of xxxxx.

Reviewer Comment (2019-07-31): AMC received the amended escrow instructions with purXXXXXX price reduction from xxxx to xxx dated 6/4/19. Buyer Comment (2019-07-30): Addendum to PurXXXXXX Agreement uploaded for review.

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

A

D

A

A

A

A

A

Non QM

Non QM

No

207902077

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.40320% is in excess of allowable threshold of Prime Mortgage Market Rate 3.39000% + 1.75%, or 5.14000%.  Compliant SubPrime Loan.

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902078

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow Borrower's company, XXXXXX , in existence since XXXX18 (16 months) vs. program requirement that the borrower must have been continually self-employed for two years

Borrower has 1 open mortgage reporting 0x30x12 since inception. Credit history reflects paid as agreed since inception of earliest account opened XXXXXX, except for one isolated 30 day late XXXXXX. No public records Borrower has been in the same line of business for past 20 years XXXXXX Reserves are 46.76 months, 43.76 months > program requirement of 3 months Credit score is 746, 66 points > program requirement of 680 LTV is 59.701%, 30.299% < program maximum of 90%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-07-31): Client has elected to waive this exception based on compensating factors.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902078

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902079

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Missing copy of Lender's Approval as required.

Reviewer Comment (2019-07-31): AMC received the loan approval dated 7/XX19. Buyer Comment (2019-07-31): See trailing document

07/31/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902079

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Missing copy of the List of Homeownership Counseling Organizations provided to borrower.

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902079

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Timing

File does not evidence the consumer was provided with the Servicing Disclosure within 3 days of the loan application date.

Missing evidence borrowers were provided a copy of the disclosure at time of application vs. at time of closing.

Buyer Comment (2019-07-31): XXXXXX has elected to waive this exception.

07/31/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902079

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $26,314.00 may be required.

Missing copy of Loan Estimate issued to borrowers at time of application.

Reviewer Comment (2019-07-31): AMC received the LE;s dated 7/XX19, 6/XX19 and 1/XX19. Buyer Comment (2019-07-31): See trailing documents

07/31/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902079

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

No cure provided on the final CD.

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902079

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No COC or cure provided for the addition of the CDA on the XXXX19 LE was not disclosed on the initial LE.

Reviewer Comment (2019-08-05): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Buyer Comment (2019-08-02): Cure documents provided

08/05/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902079

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

Reviewer Comment (2019-08-05): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

08/05/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902080

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

-

Exception granted by lender

Credit Score of 664 is 4 points greater than program requirement of 660 12.08 months reserves >3  months guideline minimum 60% LTV < 80% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-01): Client has elected to waive this exception based on compensating factors.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902080

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided within Three Days of Application)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower within three days of application.

Disclosure dated XXXX19 > 3 days of application.

Reviewer Comment (2019-08-05): Initial disclosure provided. Buyer Comment (2019-08-02): Disclosure provided

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902080

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.14370% or Final Disclosure APR of 7.17300% is in excess of allowable threshold of Prime Mortgage Market Rate 4.14000 + 1.75%, or 5.89000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-08-05): Initial disclosure provided. Buyer Comment (2019-08-02): See trailing documents

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902080

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for homeowner's insurance under Prepaids.

Section F item 1 number of months is blank.

Buyer Comment (2019-08-01): XXXXXX has elected to waive this exception.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902080

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception for HELOC 2nd mortgage paid of at closing is a collection (foreclosure never initiated)

Credit Score of 664 is 4 points greater than program requirement of 660 12.08 months reserves >3  months guideline minimum 60% LTV < 80% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-01): Client has elected to waive this exception based on compensating factors.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902080

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.14370% or Final Disclosure APR of 7.17300% is in excess of allowable threshold of Prime Mortgage Market Rate 4.14000 + 1.75%, or 5.89000%.  Compliant SubPrime Loan.

Buyer Comment (2019-08-05): XXXXXX has elected to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902082

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

DTI of 43.179% exceeds max allowed of 43%.  Approved Lender Exception in file.

One open mortgage reflects 0x30 since inception XXXXXX.  Two closed mortgages reflect paid as agreed. Credit history reflects paid as agreed since paid collection in XXXXXX Borrower has been self-employed for the past 7 years as XXXXXX Credit score is 710, 30  points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-01): Client has elected to waive this exception based on compensating factors.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902082

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided a copy of the Loan Originator Compensation disclosure  at time of application.

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902082

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 43.17703% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Loan does not meet ATR requirements due to DTI of 43.179% exceeding max allowed of 43%.  Approved Lender Exception in file.

One open mortgage reflects 0x30 since inception XXXXXX.  Two closed mortgages reflect paid as agreed. Credit history reflects paid as agreed since paid collection in XXXXXX Borrower has been self-employed for the past 7 years as XXXXXX Credit score is 710, 30  points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-01): Client has elected to waive this exception based on compensating factors.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902082

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $675.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing.

Initial LE reflects an appraisal fee of $650 yet the final CD shows a charge of $675.  Lender provided sufficient cure to borrower.

07/31/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207902082

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Dwelling coverage of $xxxxx was insufficient to cover loan amount of $xxxxx.

Reviewer Comment (2019-08-06): Revised evidence of insurance provided. Buyer Comment (2019-08-05): Corrected HOI for review

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

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

Reviewer Comment (2019-08-14): 12 months bank statements provided. Reviewer Comment (2019-08-09): Documentation submitted is not one of the acceptable forms per the lender guidelines Section 5.8. Guidelines do not indicate that FNMA guidelines a acceptable in lieu of lender guidelines. An investor approved exception is required. Buyer Comment (2019-08-08): FNMA guidelines allow for bank statement: Rental Payment History The borrower's rental payment history must be documented for the most recent consecutive 12-month period. The following documentation is acceptable: Canceled checks can be provided. In lieu of canceled checks, the lender may use the borrower's bank statements, copies of money orders, or other reasonable methods for documenting the timely payment of rent. Reviewer Comment (2019-08-07): Statement for XXXX was provided. An investor approved exception is required to accept the bank statements as they do not meet guideline requirements. Reviewer Comment (2019-08-02): Per Guidelines:  Acceptable verification methods include verification of mortgage, verification of rent, verification of installment debt or copies of the front and back of the last 12 months' checks used to pay an obligation. Guidelines do not include statements as proof of payment. Statements provided are missing proof of XXXX payment. Buyer Comment (2019-08-01): We have 12 months bank statements in the file from XXXXXX showing the payment of $XXXX/mo which is acceptable per guidelines

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-08-12): AMC received the signed and completed ATR attestation.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.98270% or Final Disclosure APR of 6.09900% is in excess of allowable threshold of APOR 3.80% + 1.5%, or 5.30000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-08-09): AMC received the initial LE.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Right to Received Copy of Appraisal / Initial LE is missing from file.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Right to Received Copy of Appraisal / Initial LE is missing from file.

Reviewer Comment (2019-08-09): Initial LE dated XXXXXX provided

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Servicing Disclosure / Initial LE is missing from file.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit is missing from file.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

XXXX19 CD not provided w/in 3 business days prior to closing XXXX19.

Reviewer Comment (2019-08-09): SitusAMC received required documents, exception is cleared.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $8,928.05 may be required.

LE(s) are missing from file.

Reviewer Comment (2019-08-09): SitusAMC received required documents, exception is cleared.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $8,928.05 and disclosure timing violations.

Consent form not located in the loan file.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

E-consent form not located in the loan file.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

E-consent form not located in the loan file.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

SSPL not located in loan file.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,404.05 exceeds tolerance of $1,089.00 plus 10% or $1,197.90.  Insufficient or no cure was provided to the borrower.

E-consent form not located in the loan file.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $3,618.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

E-consent form not located in the loan file.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee.  Fee Amount of $175.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

E-consent form not located in the loan file.

Reviewer Comment (2019-08-14): SitusAMC received required documents, exception is cleared.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902083

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee.  Fee Amount of $175.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

No Changed circumstance to allow for fee increase.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902084

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902085

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Reviewer Comment (2019-08-02): AMC received the final title with coverage of $xxxx.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902085

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date XXXXXX, Transaction Date:  XXXXXX

Reviewer Comment (2019-08-14): AMC received the revised policy with effective dates as 7/XX19-7/XX20. Buyer Comment (2019-08-14): Please see revised dec page

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902085

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

Seller CD does not reflect any seller fees

Reviewer Comment (2019-08-07): AMC received seller's CD. Exception Cleared. Buyer Comment (2019-08-06): Please see PCCD, LOE Reviewer Comment (2019-08-05): Seller CD and Buyer CD reflect no seller paid fees. PurXXXXXX contract confirms seller responsible for certain fees and commissions

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902085

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-02): AMC received the final title with coverage of $xxxx Buyer Comment (2019-08-02): Please see FINAL POLICY

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902085

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD page 3 in the section by which the total closing costs exceed the legal limit is blank. Actual amount to cure is $25.00   No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-08-07): Tolerance exceptions are addressed. Exception Cleared. Buyer Comment (2019-08-06): Please see PCCD, LOE, CHECK LABEL

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902085

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Verification fee was added for $25.00 without a valid change circumstance (VCC). Tolerance exceeded. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-08-05): cleared - please see new exception for Verification Of Tax Return Fee Buyer Comment (2019-08-02): Can you please confirm which fee you are referring to as none of the fees on the Final CD are labeled Verification Fee

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902085

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Realtor Credit (Interested Third Party) issued on final CD. Sales price to be reduced dollar for dollar.

Reviewer Comment (2019-08-05): IPC max per guidelines and FNMA is 6%. Contribution per final CD was $500. No reduction in sales price is required. Buyer Comment (2019-08-02): Please see GUIDELINE IPC reflecting Interested party contributions are allowed up to 6%

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902085

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Tax Return Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Added XXXXXX:  The XXXXXX LE added a Verification Of Tax Return Fee without a valid COC. Cure due to borrower.

Reviewer Comment (2019-08-07): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-08-06): Please see PCCD, LOE, CHECK LABEL

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902085

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Verification Of Tax Return Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2019-08-07): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902087

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Disclosure is missing.

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902087

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Initial CD signature and signature date are not present to support date of receipt.

Reviewer Comment (2019-08-02): Evidence of earlier receipt provided. Buyer Comment (2019-08-02): CD Tracking uploaded for review.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902087

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Borrower does not have the minimum active tradelines per guidelines.

Lender acknowledged exception to allow Borrower with 1 revolving account opened 4 months and 2 authorized user accounts (33 and 99 months) vs. program requirement of a minimum of at least two active tradelines and 1 inactive tradeline reporting for at least 12 months. (Note: Borrower has a supplement showing satisfactory payment history for xxxxx as an alternate tradeline _

Never a late payment and no public records. Borrower has been XXXXXX for the past 7 years and has been in the same line of work (XXXXXX) for the past 12 years. 14.84 months of reserves , 8.84 months > program requirement of 6 months. Credit score is 752, 72 points > program requirement of 680 LTV is 85%, 5% < program maximum of 90%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-01): Client has elected to waive this exception based on compensating factors.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902087

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,200.00 exceeds tolerance of $825.00.  Sufficient or excess cure was provided to the borrower at Closing.

Appraisal Fee increased from $825.00 to $1,200.00 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure provided to Borrower.

08/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.71360% or Final Disclosure APR of 5.73800% is in excess of allowable threshold of APOR 3.87% + 1.5%, or 5.37000%.  Non-Compliant Higher Priced Mortgage Loan.

APR test results of 5.73% exceeds max allowed of 5.37%.

Reviewer Comment (2019-08-21): Second appraisal fee refunded to borrower. Loan is HPML Compliant. Reviewer Comment (2019-08-19): We can cure to EV2-B and HPML Compliant once we have confirmation the check has been delivered. While we have a Fedex mailing label provided that shows a ship date of 8/XX19, the Fedex site only shows the label has been created and the package is not yet in transit. AMC is in receipt of the PCCD, LOE, copy of the check and mailing label. Reviewer Comment (2019-08-07): To cure this condition, provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property.  (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) Buyer Comment (2019-08-06): See trailing documents

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Did Not Obtain 2 Appraisals)

TILA HPML Appraisal Rule  (Dodd-Frank 2014): Flipped Property - Creditor did not obtain two (2) written appraisals.

HPML loan and property flipped within 6 months and increase in value exceeded 20% requiring 2 appraisals yet only 1 appraisal in file.

Reviewer Comment (2019-08-02): Second appraisal received. Buyer Comment (2019-08-01): 2nd appraisal provided

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Missing evidence borrower was provided the List of Homeownership Counseling Organizations at time of application.

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902088

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML) Connecticut Non-Prime Home Loan (APR Exceeds Non-Prime Threshold)

XXXXXX Non-Prime Home Loan: APR on subject loan of 5.71360% or Final Disclosure APR of 5.73800% is in excess of allowable threshold of APOR 3.87% + 1.5%, or 5.37000%.  Non-Compliant Loan.

Non Prime APR test results of 5.73% exceeds max 5.375% allowed per state of XXXXXX.

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902088

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) Connecticut Non-Prime Home Loan (Counseling Notice Not Provided)

XXXXXX Non-Prime Home Loan (HB5577): Counseling Notice (with toll-free number) not provided to borrower.

Missing evidence borrower was provided a copy of the state of CT Counseling Notice.

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD does not reflect an amount by which the fees exceeded the legal limit.

Reviewer Comment (2019-08-05): COC for 2nd appraisal provided

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence borrower was provided a copy of the Home Loan Toolkit Disclosure at time of application.

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $400.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE does not reflect a Second Appraisal fee yet the final CD shows a charge in the amount of $400.

Reviewer Comment (2019-08-05): COC for 2nd appraisal provided Buyer Comment (2019-08-02): COC provided 6/XXXX shows 2nd appraisal fee added per Credit UW condition added requesting after review of 1st appraisal. Buyer Comment (2019-08-02): See trailing documents

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-08-07): Documentation provided shows appraisal with an effective date of XXXXXX was provided to the borrower on XXXXXX. Buyer Comment (2019-08-06): Evidence borrower received a copy of valuation provided

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Borrower Charged for 2 Appraisals)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Flipped Property - Creditor improperly charged consumer for two (2) appraisals.

Reviewer Comment (2019-08-19): Proof of delivery, LOE, copy of check for $480.00 and Corrected PCCD. Buyer Comment (2019-08-19): Cure documents provided Reviewer Comment (2019-08-07): To cure this condition, provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property.  (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter) Buyer Comment (2019-08-06): COC provided with prior trailing documents showing 2nd appraisal disclosed upon condition issuance by XXXXXX UW

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Provide evidence of the refund of the amount charged to the consumer for the second appraisal performed on the subject property.  (Include a copy of the Refund Check, Proof of Delivery, and Cover Letter)

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902088

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-08-08): XXXXXX has elected to waive this exception.

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902089

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

The August XX bank statement used for calculating bank statement income is missing from the loan file.

Reviewer Comment (2019-08-05): August statement provided. Buyer Comment (2019-08-02): See attached

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902089

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-05): XXXXXX Elects to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902089

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD does not reflect an amount by which the fees exceeded the legal limit.

Buyer Comment (2019-08-05): XXXXXX Elects to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902089

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $650.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The initial LE does not reflect a Survey fee yet the final CD shows a charge in the amount of $650.

Reviewer Comment (2019-08-07): Letter of Explanation, Proof of Delivery, and Corrected CD provided.  Survey Fee moved to Section H.  Cure check not required Buyer Comment (2019-08-06): Please see attached - PCCD, LOE and Shipping Label Reviewer Comment (2019-08-05): AMC reviewed the exception. The Survey Fee was disclosed on section H on the LE indicating it is an optional service. Please provide COC if available if it was then required by lender. Please provide an attestation if it was then required by chosen provider. If it was an optional service the fee should be placed in section H with an LOE to cure. Buyer Comment (2019-08-02): Survey fee of $750 is on the initial LE sec H as reuired by the purXXXXXX contract section 11.  Buyers responsibility to obtain a survey.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902090

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-08-12): ATR provided

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Missing e-sign consent agreement.

Reviewer Comment (2019-08-08): Corrected application date per correct initial 1003 to 7/XX19 and removed incorrect LE dated 5/XX19 associated with that incorrect loan number.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Reviewer Comment (2019-08-12): ARM Disclosure dated XXXXXX provided Reviewer Comment (2019-08-07): Documentation is required that the ARM disclosure was provided to the borrower within 3 business days of application or product change from Fixed to ARM. Initial Application dated XXXXXX was a Fixed rate product. Missing valid Change of Circumstance showing product change.. Loan Estimate dated XXXXXX was for a Fixed Rate product and LE dated XXXXXX is for an ARM product. Buyer Comment (2019-08-06): the initial LE was sent and signed on X/XX which is the same day as the app

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Reviewer Comment (2019-08-08): CHARM booklet provided.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $17,743.55 and disclosure timing violations.

E-sign consent missing.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

Seller CD missing from the file. No seller fees disclosed on borrower's final CD.

Reviewer Comment (2019-08-09): Seller CD provided.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for various 0% tolerance violations of $9,001.08 was not provided.

Reviewer Comment (2019-08-08): Corrected application date per correct initial 1003 to 7/XX19 and removed incorrect LE dated 5/XX19 associated with that incorrect loan number.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $7,082.08 exceeds tolerance of $6,197.00.  Insufficient or no cure was provided to the borrower.

Fee disclosed as $6,197 on initial LE, but disclosed as $7,082.08 on Final Closing Disclosure. Fee was re-disclosed to $7,082 on LE dated XXXXXX, but the file does not have a valid change of circumstance for the increase in fee. No cure provided.

Reviewer Comment (2019-08-08): Corrected application date per correct initial 1003 to 7/XX19 and removed incorrect LE dated 5/XX19 associated with that incorrect loan number.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,300.00 exceeds tolerance of $475.00.  Insufficient or no cure was provided to the borrower.

Fee disclosed as $475 on initial LE, but disclosed as $1,300 on Final Closing Disclosure. Fee was re-disclosed to $1,300 on LE dated XXXXXX, but the file does not have a valid change of circumstance for the increase in fee. No cure provided.

Reviewer Comment (2019-08-08): Corrected application date per correct initial 1003 to 7/XX19 and removed incorrect LE dated 5/XX19 associated with that incorrect loan number.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee.  Fee Amount of $165.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Fee was not disclosed on initial LE, but disclosed as $165 on Final Closing Disclosure. Fee was re-disclosed to $165 on LE dated XXXXXX, but the file does not have a valid change of circumstance for the increase in fee. No cure provided.

Reviewer Comment (2019-08-08): Corrected application date per correct initial 1003 to 7/XX19 and removed incorrect LE dated 5/XX19 associated with that incorrect loan number.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXX exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Fee was not disclosed on initial LE, but disclosed as $7,126.47 on Final Closing Disclosure. Fee was re-disclosed to $7,126 on LE dated XXXXXX, but the file does not have a valid change of circumstance for the increase in fee. No cure provided.

Reviewer Comment (2019-08-08): Corrected application date per correct initial 1003 to 7/XX19 and removed incorrect LE dated 5/XX19 associated with that incorrect loan number.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Service Provider Timing

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

List of service providers in file is dated XXXXXX. Application date is XXXXXX.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902090

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Missing the E-consent

Reviewer Comment (2019-08-13): AMC received the e-consent dated 7/XXXX.

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902091

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Insurance in effect XXXXXX, after loan disbursement date of XXXXXX.

Reviewer Comment (2019-08-02): AMC received the revised HOI with effective dates 7/XX19-7/XX20. Buyer Comment (2019-08-02): Please see REVISED HOI

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902091

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902091

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids of $1,648 that does not match amount per month calculation of $114.17.

Reviewer Comment (2019-08-05): PurXXXXXX transaction HOI policy received confirms $1,648 was due at closing.  Of the $1648 that was due $278 was a non re-occurring agency fee and $1,370 is the actual premium. Lender disclosed HOI correctly. Buyer Comment (2019-08-02): Please see HOI reflecting Actual annual premium is $1,370 with $278 fee reflecting as a "Non Recurring" agency fee which would not be included in the monthly HOI payment

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902091

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for Title - Endorsement Fee of $185.25 was not provided.

Reviewer Comment (2019-08-07): Tolerance exceptions are addressed. Exception Cleared. Buyer Comment (2019-08-06): Please see PCCD, LOE, CHECK LABEL

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902091

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $185.25 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Fee was not disclosed on Loan Estimate.

Reviewer Comment (2019-08-07): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-08-06): Please see PCCD, LOE, CHECK LABEL

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902091

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

File only contains recent 1 month statement. Other statement in file for the accounts is dated XXXXXX, 1 year old.

Reviewer Comment (2019-08-05): Additional Statement provided. Buyer Comment (2019-08-02): Please see XXXXXX April-May and XXXXXX May-June

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902091

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

The borrower is self-employed.  Guidelines require either a tax professional letter or regulatory agency verifying at least 2 years of self-employment along with either a phone listing and/or business address using directory assistance or internet search to be in file.

Lender approved exception. Borrower's company, xxxxx, has been in existence since XXXXXX (22 months) vs program requirement that the borrower must be continually self-employed for 2 years.

LTV is 80% < program maximum of 90% Perfect credit history since inception of earliest account opened XXXXXX. VOR reflects paid as agreed since inception in XXXXXX No public records 12.29 months reserves > 3 months guideline minimum 38.51% DTI < 43% guideline max 777 representative FICO score > 680 guideline minimum - 97 points above guideline minimum.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-01): Client has elected to waive this exception based on compensating factors.

08/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902091

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $185.25 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-08-07): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902092

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Questionable Occupancy: Valuation occupancy differs from occupancy on loan approval.

-

Appraisal indicates subject property is vacant, however subject photos indicate the property is occupied

Reviewer Comment (2019-08-29): Affidavit of Occupancy and Loan application confirm occupancy as a second home. Buyer Comment (2019-08-28): The appraiser XXXXXX indicates that the property is presently vacant, as it is utilized as a secondary residence.  He indicated that he is complying with USPAP in denoting present occupancy.  The home is utilized as a secondary home, as denoted by AMC, you can see the Borrowers personal effects etc. throughout the dwelling.  Please see Affidavit of Occupancy.

08/29/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application

RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Reviewer Comment (2019-08-09): SitusAMC received required documents, exception is cleared.

08/09/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

SSPL is not located in file.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,641.50 exceeds tolerance of $1,208.00.  Insufficient or no cure was provided to the borrower.

Loan Discount Points increased from $1,208 to $2,641.50 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-08-09): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-08): uploaded LEs and COCs

08/09/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902092

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXX exceeds tolerance of $1,155.00.  Insufficient or no cure was provided to the borrower.

Transfer Tax Fee increased from $1,155 to $1,237.50 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-08-09): SitusAMC received required documents, exception is cleared.

08/09/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902093

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2019-08-05): Appraisal provided. Buyer Comment (2019-08-02): Appraisal uploaded for review.

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

B

B

C

A

Non QM

Non QM

No

207902093

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2019-08-05): Appraisal provided. Buyer Comment (2019-08-02): Appraisal uploaded for review.

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

B

B

C

A

Non QM

Non QM

No

207902093

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Reviewer Comment (2019-08-05): Appraisal provided. Buyer Comment (2019-08-02): Appraisal uploaded for review.

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

B

B

C

A

Non QM

Non QM

No

207902093

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided the LO Compensation Disclosure at time of application.

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

B

B

C

A

Non QM

Non QM

No

207902094

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower.

Missing evidence borrower was provided the Counseling Disclosure at time of application.

Reviewer Comment (2019-08-13): XXXXXX Counseling Disclosure with list of Counselors provided. Buyer Comment (2019-08-12): XXXXXX Subprime Counseling disclosure provided

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902094

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.89650% is in excess of allowable threshold of Prime Mortgage Market Rate 3.39000% + 1.75%, or 5.14000%.  Non-Compliant SubPrime Loan.

State APR test results of 6.8965% exceeds max allowed of 5.14%.

Reviewer Comment (2019-08-13): Compliance re-run. Condition reset as Compliant Buyer Comment (2019-08-12): See Trailing documents

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence borrower was provided the Home Loan Toolkit at time of application.

Buyer Comment (2019-08-05): XXXXXX has elected to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Missing evidence borrower received the CD a minimum of 3 business days prior to closing.

Reviewer Comment (2019-08-06): AMC received XX08 CD. Exception Cleared. Buyer Comment (2019-08-05): Initial CD provided

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902094

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/8/XX 12:00:00 AM was received.

AMC received XX08 CD. The XX03 LE does not indicated of receipt therefore the mailbox rule is used. Please provide earlier receipt if available.

Buyer Comment (2019-08-12): XXXXXX has elected to waive this exception.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902094

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.89650% is in excess of allowable threshold of Prime Mortgage Market Rate 3.39000% + 1.75%, or 5.14000%.  Compliant SubPrime Loan.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Hazard Insurance Policy Effective Date XXXXXX, Transaction Date:  XXXXXX

Reviewer Comment (2019-08-14): Agree with lender. Closing date on final closing statement is same as effective date. Buyer Comment (2019-08-13): XXXXXX "Escrow State" Buyer Comment (2019-08-13): XXXXXX non Escrow State - PCCD provided showing close date. Please clear.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-13): AMC received the final title dated 7/XX19 for $xxxx. Buyer Comment (2019-08-13): Revised Title provided

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Reviewer Comment (2019-08-13): AMC received the final title dated 7/XX19 for $xxx.

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Reviewer Comment (2019-08-09): 4506T PROVIDED. Buyer Comment (2019-08-07): See trailing documents

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Lender on the appraisal is XXXXXX

Reviewer Comment (2019-08-09): Per google search, agree with lender. Buyer Comment (2019-08-07): XXXXXX and XXXXXX are one and the same - please clear

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Missing proof or receipt of Deposit for REO (converted from primary to investment) located at XXXXXX per lender final approval.

Reviewer Comment (2019-08-09): Deposit for REO provided. Buyer Comment (2019-08-07): REO documents provided

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX-  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-08-14): Borrower Ability to Repay Attestation provided Buyer Comment (2019-08-13): Revised ATR Attestation provided Reviewer Comment (2019-08-12): AMC received the ATR attestation signed however the form is not completed as no items have been selected and initialed as required. Buyer Comment (2019-08-09): ATR Attestation re-uploaded for review Reviewer Comment (2019-08-09): ATR Attestation not in trailing docs. Buyer Comment (2019-08-07): ATR Attestation provided

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

B

A

Non QM

Non QM

No

207902095

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Borrower Paid Loan Costs Total Section B

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX disclosed Total Services Borrower Did Not Shop For (Section B) that does not match sum of fees.

Final CD moved fees from Borrower to Seller paid.  Did not change the total box for section B. Showing $4,916.60 when actual Borrower cost is $466.60

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

B

A

Non QM

Non QM

Yes

207902095

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Costs Subtotals Borrower Paid - Before Closing

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on  XXXXXX disclosed Total Closing Costs (Paid by Borrower Before Closing) that does not match sum of fees.

Final CD moved fees from Borrower to Seller paid.  Did not change the total box for section B. Showing $4,916.60 when actual Borrower cost is $466.60

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

B

A

Non QM

Non QM

Yes

207902096

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-05): XXXXXX has elected to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902096

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD page 3 in the section by which the total closing costs exceeded the legal limit indicates a cure of $3.18. Actual cure is $47.00.  No evidence in file that cure was provided to Borrower.

Buyer Comment (2019-08-05): XXXXXX has elected to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902096

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $1,134.00 exceeds tolerance of $1,102.00.  Insufficient or no cure was provided to the borrower.

Loan Discount points increased from $1,102.00 to $1,134.00 without a valid change circumstance (VCC). Tolerance exceeded. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-08-06): COC - loan amount increase Buyer Comment (2019-08-05): 7/19 change of circumstance loan uploaded.

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902096

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $53.18 exceeds tolerance of $50.00.  Insufficient or no cure was provided to the borrower.

Credit Report Fee increased from $50.00 to $53.18 without a valid change circumstance (VCC). Tolerance exceeded. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-08-06): $3.18 cure provided to the borrower at closing. Buyer Comment (2019-08-05): Lender credit of $3.18 was issued on final CD under section J.

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902096

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $53.18 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower at Closing.

$3.18 cure provided to the borrower at closing.

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902097

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-05): XXXXXX has elected to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902097

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for 0% tolerance violations of $100 was not provided.

Buyer Comment (2019-08-05): XXXXXX has elected to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902097

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges.  Fee Amount of $60.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Fee was not disclosed on Loan Estimate

Reviewer Comment (2019-08-14): AMC received PCCD correcting service provider. Exception Cleared. Buyer Comment (2019-08-13): Please see attached PCCD, LOX and Label. Reviewer Comment (2019-08-08): AMC reviewed the exception. Please provide the address for the First American Title used to determine if it is the provider listed on the SSPL which determines tolerance thresholds. Buyer Comment (2019-08-07): The fees denoted are fees that the Borrower has the ability to shop for, the question would be is the company chosen an affiliate, the CFPB defines "affiliate" as "any company that controls, is controlled by, or is under common control with, your company".  The company is listed on the provider list however they are not an affiliate and therefore would fall into the 10% tolerance bucket, not zero tolerance. Reviewer Comment (2019-08-06): The Final CD has the fee being paid to First American Title which is the same provider listed on the SSPL and subject to 0% tolerance.  If the borrower utilized First American Title please provide address of First American Title that the borrower used.  Title Commitment in the loan file is from xxxx.  If borrower utilized xxxx for title fees then a Post Close CD and LOE required correcting the fee names from First American Title to xxxxis required. Buyer Comment (2019-08-05): Within 10 % tolerance

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902097

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $40.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Fee was not disclosed on Loan Estimate

Reviewer Comment (2019-08-14): Tolerance exceptions are addressed. Exception Cleared. Reviewer Comment (2019-08-08): AMC reviewed the exception. Please provide the address for the First American Title used to determine if it is the provider listed on the SSPL which determines tolerance thresholds. Buyer Comment (2019-08-07): The fees denoted are fees that the Borrower has the ability to shop for, the question would be is the company chosen an affiliate, the CFPB defines "affiliate" as "any company that controls, is controlled by, or is under common control with, your company".  The company is listed on the provider list however they are not an affiliate and therefore would fall into the 10% tolerance bucket, not zero tolerance. Reviewer Comment (2019-08-06): The Final CD has the fee being paid to xxxx which is the same provider listed on the SSPL and subject to 0% tolerance.  If the borrower utilized xxxx please provide address of xxxx that the borrower used.  Title Commitment in the loan file is from xxxx.  If borrower utilized xxx for title fees then a Post Close CD and LOE required correcting the fee names from First American Title to xxxx is required. Buyer Comment (2019-08-05): Within 10 % tolerance

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902097

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception. Initial earnest money deposit of $xxxx is from business account (CPA letter for business use of funds is pending and being obtained) vs program requirement that all funds towards the transaction must be from a personal account.

20.33 months reserves > 3 months guideline minimum Borrower has been in the same line of work (XXXXXX) for the past 30 years DTI is 37.46% < program maximum of 50% Credit score is 659, 19 points > program requirement of 640 LTV is 80%, 5% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-02): Client has elected to waive this exception based on compensating factors.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902097

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow ownership change from XXXXXX and use combination of current and previous company 12 months of bank statements vs program requirement of 12 full months business bank statements for current business used to qualify.

20.33 months reserves > 3 months guideline minimum Borrower has been in the same line of work (XXXXXX) for the past 30 years DTI is 37.46% < program maximum of 50% Credit score is 659, 19 points > program requirement of 640 LTV is 80%, 5% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-02): Client has elected to waive this exception based on compensating factors.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902098

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Per guidelines, "if Foreign Borrower self-employment income is verified by a certified public accountant, a copy of the accountant's license must be included in the Mortgage File." CPA Letter was used to verify the borrower's self-employed income yet we do not have a copy of the accountant's license as required.

Foreign borrower with US credit and active tradelines paid as agreed and current. No public records. Borrower has been self-employed for the past 7 years as XXXXXX 33.40% DTI < 50.00% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-26): Client elects to waive the exception with verified compensation factors. Buyer Comment (2019-08-23): Uploaded For Review-Exception Approval Reviewer Comment (2019-08-09): Per translation, the name of the Head Accountant is XXXXXX. The translation provided for the CPA License is a Certification of State title Registration with the type of title being Real estate property. The document does not refer to the CPA that prepared the letter. Buyer Comment (2019-08-08): Uploaded For Review- CPA License Reviewer Comment (2019-08-08): Documentation provided does not confirm that the individual signing the CPA letter is licensed as an accountant. Buyer Comment (2019-08-07): Uploaded For Review-CPA License

08/26/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902098

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Lender approved exception to allow the LTV of 67% vs program maximum of 65%

Foreign borrower with US credit and active tradelines paid as agreed and current. No public records. Borrower has been self-employed for the past 7 years as XXXXXX 33.40% DTI < 50.00% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-05): Client has elected to waive this exception based on compensating factors.

08/05/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902098

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Lender approved exception to allow loan amount of $xxxxx vs program maximum of $3,000,000 (at 65% LTV)

Foreign borrower with US credit and active tradelines paid as agreed and current. No public records. Borrower has been self-employed for the past 7 years as XXXXXX 33.40% DTI < 50.00% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-05): Client has elected to waive this exception based on compensating factors.

08/05/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902098

XXXXXX

XXXXXX

Credit

System

General

Valuation address does not match Note address.

-

Valuations reflect the standardized city of "XXXXXX" versus "XXXXXX" and "XXXXXX" as reflected on the 1003 and title.

Reviewer Comment (2019-08-12): Corrected Appraisals provided. Buyer Comment (2019-08-09): Uploaded For Review: Corrected Appraisals

08/12/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902098

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Disclosure missing

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902098

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception. Due to tax ramifications borrower would like subject second home to remain in the same of the corporation, XXXXXX instead of borrower's name vs program requirement that only investment properties can be in an LLC or a corporation.

Foreign borrower with US credit and active tradelines paid as agreed and current. No public records. Borrower has been self-employed for the past 7 years as XXXXXX 33.40% DTI < 50.00% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-05): Client has elected to waive this exception based on compensating factors.

08/05/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902098

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception. Loan to close with a POA. Borrower will have his US based attorney, XXXXXX , who is already authorized to sign on behalf of the XXXXXX , however, she cannot sign on behalf of the borrower due to a potential conflict of interest between corporation and the borrower. Exception is for borrower's father who lives here to sign on his behalf as the POA.

Foreign borrower with US credit and active tradelines paid as agreed and current. No public records. Borrower has been self-employed for the past 7 years as XXXXXX 33.40% DTI < 50.00% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-05): Client has elected to waive this exception based on compensating factors.

08/05/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902099

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

missing

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902099

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

Colorado Home Loan (Ability to Repay not Verified)

XXXXXX Home Loan (HB1322):  Borrower's ability to repay not verified with reliable documentation.

File does not contain third party verification of self employment at time of close per ATR requirements

Buyer Comment (2019-08-02): XXXXXX has elected to waive this exception.

08/02/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902099

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-05): Conditional Approval provided Buyer Comment (2019-08-02): Approval uploaded for review.

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902100

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $206.00 exceeds tolerance of $134.00.  Sufficient or excess cure was provided to the borrower at Closing.

Evidence of sufficient cure for fee increase not provided.

08/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

207902103

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-08-07): Fraud report provided

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902103

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.28660% or Final Disclosure APR of 8.31700% is in excess of allowable threshold of APOR 3.80% + 1.5%, or 5.30000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-08-07): Appraisal provided XXXXXX. Buyer Comment (2019-08-06): See trailing documents

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902103

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902103

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Reviewer Comment (2019-08-07): Appraisal provided XXXXXX. Buyer Comment (2019-08-06): See trailing documents

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902103

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Reviewer Comment (2019-08-07): AMC received LE. Exception Cleared. Buyer Comment (2019-08-06): See LE page 3 "Other Consideration"

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902103

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

File does not evidence the consumer was provided with the Servicing Disclosure.

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902103

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902103

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/XXXXXX)

Reviewer Comment (2019-08-07): AMC received initial CD. Exception Cleared. Buyer Comment (2019-08-06): Initial CD and COC CD provided

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902103

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $14,187.18 may be required.

Loan Estimate not provided within loan images to evidence delivery to the Borrower(s). The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing. Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $14,187.18 may be required.

Reviewer Comment (2019-08-07): AMC received LE. Exception Cleared. Buyer Comment (2019-08-06): LE's and COC's provided - Econsent and SSPL included

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902104

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Dates entered as reported

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902104

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Loan Underwriting and Transmittal Summary (1008) / MCAW not provided

Reviewer Comment (2019-08-07): AMC received a copy of the 1008 transmittal dated 7/XX19. Buyer Comment (2019-08-06): 1008 uploaded for review.

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902105

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception for business in existence for 19 months, minimum requirement is 24

No public records. Borrower has employment stability for 8 years in the XXXXXX field 5.77 Months of reserves, 2.77 months greater than required 3 months 786 representative FICO score > 680 guideline minimum - 106 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-05): Client has elected to waive this exception based on compensating factors.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902106

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-05): XXXXXX has elected to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902106

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Revised LE was received the  same day as the initial CD.

Buyer Comment (2019-08-05): XXXXXX has elected to waive this exception.

08/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902108

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

Reviewer Comment (2019-08-08): Account was on final 1003, however not necessary to qualify. Buyer Comment (2019-08-07): Account not used for qualifying - see UW final 1003 provided

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902108

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Buyer Comment (2019-08-07): XXXXXX has elected to waive this exception.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902108

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXX exceeds tolerance of $1,976.25.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $1,977.00 exceeds tolerance of $1,658.00.  Missing proof of valid change, insufficient or no cure was provided to the borrower

Reviewer Comment (2019-08-09): COC - provided Buyer Comment (2019-08-08): Final CD section J. reflects Lender credit of $0.75 for CC over limit

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902108

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Administration Fee.  Fee Amount of $1,150.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Administration Fee. Fee Amount of $1,150.00 exceeds tolerance of $0.00. Missing proof of valid change, insufficient or no cure was provided to the borrower

Reviewer Comment (2019-08-09): COC - investor changed - new fee per new investor. Buyer Comment (2019-08-08): Fee added on COC - see disclosure tracking

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902108

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXX exceeds tolerance of $1,976.25.  Sufficient or excess cure was provided to the borrower at Closing.

$0.75 cure provided at close.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902110

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Missing Document: Security Instrument not provided

Reviewer Comment (2019-08-09): Mortgage, exhibit D, provided. CEMA Agreement including Exhibits A, B and C in file Buyer Comment (2019-08-07): Mortgage provided

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing documentation

Reviewer Comment (2019-08-12): SitusAMC received required documents, exception is cleared.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Good faith redisclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.41970% or Final Disclosure APR of 5.42500% is in excess of allowable threshold of APOR 3.79% + 1.5%, or 5.29000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-08-12): Appraisal provided on XXXXXX.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Missing documentation

Reviewer Comment (2019-08-12): SitusAMC received required documents, exception is cleared.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Good faith redisclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Missing documentation

Buyer Comment (2019-08-09): XXXXXX has elected to waive this exception.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Good faith redisclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

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

Buyer Comment (2019-08-09): XXXXXX has elected to waive this exception.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $17,603.82 may be required.

Missing documentation

Reviewer Comment (2019-08-12): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-09): Econsent and SSPL also provided Buyer Comment (2019-08-09): LE's provided

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Reviewer Comment (2019-08-12): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-09): Initial CD provided

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Property Value

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed an Appraised Property Value that did not match the actual Property Value for the loan.

Final Closing Disclosure provided on XXXXXX disclosed an Appraised Property Value $xxxxx

Buyer Comment (2019-08-09): XXXXXX has elected to waive this exception.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-08-12): Appraisal provided on XXXXXX. Buyer Comment (2019-08-09): See trailing documents

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-08-12): Appraisal provided on XXXXXX. Buyer Comment (2019-08-09): Evidence borrower received valuation provided

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902110

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-08-12): XXXXXX has elected to waive this exception.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

D

B

D

A

C

B

A

A

Non QM

Non QM

No

207902111

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-08-09): Fraud Report provided

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902111

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2019-08-09): AMC received XX11 CD. Exception Cleared.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902111

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Engine Required from Mavent or ComplianceEase. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-08-09): Mavent provided.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902111

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.16460% is in excess of allowable threshold of Prime Mortgage Market Rate 3.63000% + 1.75%, or 5.38000%.  Compliant SubPrime Loan.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower.

Reviewer Comment (2019-08-12): Counseling Disclosure provided.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Non-Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.29750% is in excess of allowable threshold of Prime Mortgage Market Rate 3.46000% + 1.75%, or 5.21000%.  Non-Compliant SubPrime Loan.

Reviewer Comment (2019-08-12): Counseling Disclosure provided.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Over the legal limit

Reviewer Comment (2019-08-09): fee reconciled to section b

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902112

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing from the file

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee.  Fee Amount of $1,195.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided for this fee

Reviewer Comment (2019-08-09): fee reconciled to section b Buyer Comment (2019-08-08): settlement fee went down from $1200 to $1195

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902112

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No evidence of fraud report in file

-

Reviewer Comment (2019-08-09): Fraud Report provided Buyer Comment (2019-08-08): uploaded fraud report

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-08-09): Fraud Report provided

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

Disclosure dated XXXX19

Reviewer Comment (2019-08-09): Change of Circumstance dated XXXXXX for program change from Fixed to ARM. ARM and Charm Disclosures received by the borrower on XXXXXX.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Disclosure dated XXXX19

Reviewer Comment (2019-08-09): Change of Circumstance dated XXXXXX for program change from Fixed to ARM. ARM and Charm Disclosures received by the borrower on XXXXXX.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing the ComplianceEase or Mavent as required.

Reviewer Comment (2019-08-09): Compliance report provided

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Counseling Disclosure provided.

Buyer Comment (2019-08-12): XXXXXX has elected to waive

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902112

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.29750% is in excess of allowable threshold of Prime Mortgage Market Rate 3.46000% + 1.75%, or 5.21000%.  Compliant SubPrime Loan.

Buyer Comment (2019-08-12): XXXXXX has elected to waive

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-14): Documentation provided with correct loan amount. Reviewer Comment (2019-08-08): No updated title commitment with loan amount in trailing docs.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-08-08): Borrower Ability to Repay Attestation provided

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 72.79893% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Reviewer Comment (2019-08-12): Updated REO information. Reviewer Comment (2019-08-08): Provide additional REO documentation for review. Buyer Comment (2019-08-07): DTI < 50%

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing.

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

DTI > 50%

Reviewer Comment (2019-08-08): Adjusted rental income and S/E income.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Missing XX 1040's.

Reviewer Comment (2019-08-08): Adjusted rental income and S/E income.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-08-08): waive

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Negative rents higher than lender's calculation

Reviewer Comment (2019-08-12): Updated REO information.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI > 50%

Reviewer Comment (2019-08-12): Updated REO information.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Unable to verify S-Corp income using reasonably reliable third-party records.

Reviewer Comment (2019-08-08): Adjusted rental income and S/E income.

08/08/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Reviewer Comment (2019-08-12): Updated REO information. Reviewer Comment (2019-08-08): Provide all pages of HOI policy for XXXXXX

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Reviewer Comment (2019-08-12): Updated REO information. Reviewer Comment (2019-08-12): Per the mortgage statement provided in trailing docs, only taxes are escrowed. Insurance policy does not provided a premium breakdown for each properties listed. Provide premiums specific to each property. Buyer Comment (2019-08-09): page 5 shows that the mtg on this property escrows for both taxes and ins and we are obligating the borrower for the full PITI payment on the sched of REO. Reviewer Comment (2019-08-08): Commercial Prop Ins policy provided does not breakdown the premium for each property. Provisional Premium of $27,547.00 reflected on policy does not match the amount used on the final 1003. Provide premium breakdown for XXXXXX. Provide mtg statement to verify if taxes and ins are included in payment.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Adjusted rental income and S/E income.

Reviewer Comment (2019-08-12): Updated REO information.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Lender to provide updated ATR/QM Loan Designation

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902113

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Adjusted rental income and S/E income.

Buyer Comment (2019-08-09): waive

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902113

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Commercial Prop Ins policy provided does not breakdown the premium for each property.

Reviewer Comment (2019-08-12): Updated REO information. Buyer Comment (2019-08-09): Uploaded REO Docs - last page are the taxes and insurance because the policy does not break out for each property, the ins was taken from the tax returns sched e.  For XXXXXX, the is a condo and the taxes and HOA statements are listed under the REO documents.

08/12/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902114

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-06): XXXXXX has elected to waive this exception.

08/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902117

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Review Fee.  Fee Amount of $150.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Fee Amount of $150.00 exceeds tolerance of $0.00. Sufficient or excess cure was provided to the borrower at Closing.

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

207902118

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow primary residence loan to close in name of LLC

Excellent payment history, no derogatory accounts Reserves are 34.77 months > program requirement of 6 months Credit score is 784, 64 points > program requirement of 720 LTV is 58.824% < program maximum of 75%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-07): Client has elected to waive this exception based on compensating factors.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902118

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-07): XXXXXX has elected to waive this exception.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902118

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

Line 4 of Section F, number of months is blank.

Buyer Comment (2019-08-07): XXXXXX has elected to waive this exception.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207902118

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Compliance Engine Required from Mavent or ComplianceEase. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-08-09): Mavent provided. Buyer Comment (2019-08-08): see attached

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902119

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.28676% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Lender approved exception in file

subject property has been completely remodeled recently One open mortgage reflects 0x30 since inception XXXXXX.  Perfect credit history since inception of earliest account opened XXXXXX.  No public records. Borrower has been self- employed for the past 2 years as XXXXXX Credit score is 748, 48 points > program requirement of 700.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-07): Client has elected to waive this exception based on compensating factors.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902119

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender approved exception in file

subject property has been completely remodeled recently One open mortgage reflects 0x30 since inception XXXXXX.  Perfect credit history since inception of earliest account opened XXXXXX.  No public records. Borrower has been self- employed for the past 2 years as XXXXXX Credit score is 748, 48 points > program requirement of 700.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-07): Client has elected to waive this exception based on compensating factors.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902119

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Other not provided

Missing Lender's Deposit Analysis Worksheet to match Business Bank Statements for account XXXXXX

Reviewer Comment (2019-08-14): Income Worksheet,Analysis provided. Buyer Comment (2019-08-08): Income Worksheet,Analysis Buyer Comment (2019-08-08): Income Worksheet

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902119

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 57.06828% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

.

subject property has been completely remodeled recently One open mortgage reflects 0x30 since inception XXXXXX.  Perfect credit history since inception of earliest account opened XXXXXX.  No public records. Borrower has been self- employed for the past 2 years as XXXXXX Credit score is 748, 48 points > program requirement of 700.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-14): Client elects to waive the exception with verified compensation factors

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902119

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

.

Reviewer Comment (2019-08-14): Non-QM loan based on DTI exception addressed with compensating factors.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207902120

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $52.00 exceeds tolerance of $35.00.  Sufficient or excess cure was provided to the borrower at Closing.

Initial LE reflected a credit report fee of $35 yet the final CD shows a fee of $52.  Lender provided a $17 cure to the borrower at time of closing.

08/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

B

B

A

A

A

A

Non QM

Non QM

Yes

207902120

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow use of LOE and Secretary of State document as proof of 100% business ownership by borrower vs program requirement of acceptable documentation to verify part of the business owned by the borrower

Self-employed for the past 4 years as owner of XXXXXX, with 27 years in profession. DTI is 18.689%, 24.311% < program maximum of 43%. Credit score is 719, 39 points > program requirement of 680. Re-established credits and no late payment since BK7 discharged in XXXXXX

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-07): Client has elected to waive this exception based on compensating factors.

08/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902121

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 73,380.78 on Final Closing Disclosure provided on XXXXXX not accurate.

Lender is using 6,670.98 revieweer based on Taxes $4,226.24 a month, Insurance $752.69 and HOA's $962.83.

Reviewer Comment (2019-08-16): AMC received final settlement statement verifying HOA dues of $11331.86/year. Exception Cleared. Buyer Comment (2019-08-15): Please see final closing statement Reviewer Comment (2019-08-15): It looks like the lender is rounding up for HOA and Taxes.  The exact figures are as follows:Yearly HOA $11,554 / 12 = $962.83 1.25% of purXXXXXX price for taxes = $59,687.50 / 12 = $4,973.96 HOI $9,032.36 / 12 = $752.70 Reviewer Comment (2019-08-12): Please provided confirmation of HOA.  AMC is using $962.83 based of the appraisal. If HOA can not be verified Corrected CD and LOE to borrower required to cure.  Taxes and Insurance used by lender and AMC match.  AMC now using 1.25% of purXXXXXX price. Buyer Comment (2019-08-09): PurXXXXXX price x by the factor 1.25% since do not know  of any applicable exemptions 4,775,000x1.25%=59687.50/12=4976.96 As  such the amount of estimated property cost is  4973.96+752.70=5726.66+ HOA 944.32=6670.98x11=73380.78-  CD dated 7/XXXX is correct You are using the taxes paid by the previous owner of $4226.24 per month Please note that the HOA dues  $11331.84 ANNUALLY-11331.84/12=944.32

08/16/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902121

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Alternate Table Usage

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

Costs at Closing/ Calculating Cash to Close: Alternate tables not used consistently throughout the transaction. (w/Seller Table vs. w/out Seller).

Buyer Comment (2019-08-09): waive

08/09/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Good Faith Redisclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902121

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature. (Final/XXXXXX). (boxes blank)

Buyer Comment (2019-08-09): waive

08/09/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902122

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Non Escrowed Property cost of Year 1 of $330.00 on final CD is incorrect. HOA dues per appraisal are $300 yearly.

Reviewer Comment (2019-08-16): AMC received PCCD correcting non escrowed property costs and LOE. Exception Cured. Buyer Comment (2019-08-15): PCCD provided

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902122

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Other Compliance Exception (Manual Add)

Compliance Engine Required from Mavent or ComplianceEase. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-08-14): AMC received the Mavent dated 7/XX19 date of consummation with a Pass for TILA/RESPA, High Cost and alert on HPML, Buyer Comment (2019-08-14): Mavent uploaded for review.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902122

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Page 4 of final CD did not select whether the loan contains a demand feature.

Buyer Comment (2019-08-08): XXXXXX has elected to waive this exception.

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902123

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Approval not provided and 1008 for DTI calculations

Reviewer Comment (2019-08-15): Approval provided Buyer Comment (2019-08-15): Approval provided

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902123

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-09): XXXXXX has elected to waive this exception.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902123

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Buyer Comment (2019-08-09): XXXXXX has elected to waive this exception.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902123

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2019-08-15): AMC received the initial CD dated 7/XXXX. Buyer Comment (2019-08-14): Initial CD dated 7/XX19 provided Reviewer Comment (2019-08-13): AMC reviewed exception. The only CD in file is dated XXXX19. Please provide any earlier CDs if available. Buyer Comment (2019-08-12): Initial CD provided

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902123

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Reviewer Comment (2019-08-13): Initial SSPL provided Buyer Comment (2019-08-12): SSPL provided

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902123

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing final executed copy of settlement statement / CD for the sale of departure residence located at XXXXXX  to verify proceeds of $104,836.03.

Reviewer Comment (2019-08-15): Final seller CD provided Buyer Comment (2019-08-15): Final CD provided - please clear Reviewer Comment (2019-08-13): Provide final HUD-1/Settlement Statement/Final CD signed and dated by borrowers. Final closing statement provided is not acceptable. Buyer Comment (2019-08-12): See trailing documents Reviewer Comment (2019-08-12): Closing statement for sale of property at XXXXXX on XXXXXX was not signed or certified. Buyer Comment (2019-08-09): See final CD provided

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902123

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.53590% is in excess of allowable threshold of Prime Mortgage Market Rate 3.46000% + 1.75%, or 5.21000%.  Compliant SubPrime Loan.

Buyer Comment (2019-08-09): XXXXXX has elected to waive this exception.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902124

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrower has been XXXXXX  for the past 20 years and recently purchases two XXXXXX  only 11 months ago (XXXX - per business license) and the second 5 months ago (XXXX - per business license) with 15 employees (XXXXXX ) vs program requirement must be self employed for three years and self employment income used to qualify for the loan must have been continuously self employed for three years.

Borrower has 1 open mortgage reporting paid as agreed since inception dated XXXXXX. No derogatory and no public records. Borrowers has been XXXXXXin the same line of work for 20 years 16.11676% DTI on this bank statement documentation loan < 50.00% guideline max - 33.88324% below program guideline maximum 792 representative FICO score > 152  guideline minimum - 640 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-08): Client has elected to waive this exception based on compensating factors.

08/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902125

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-12): XXXXXX elects to waive this exception.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902125

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-12): XXXXXX elects to waive this exception.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902125

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

No cure provided

Buyer Comment (2019-08-12): XXXXXX elects to waive this exception.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902125

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Attorney Review Fee.  Fee Amount of $295.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No COC provided for increase

Reviewer Comment (2019-08-13): AMC reviewed exception. The fee was outsourced by chosen provider. Exception Cleared. Buyer Comment (2019-08-12): This is a zero tolerance fee. Borrower did not choose a provider on the written list .

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902126

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $500.00 exceeds tolerance of $490.00.  Sufficient or excess cure was provided to the borrower at Closing.

08/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

B

B

A

A

A

A

Non QM

Non QM

Yes

207902126

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

-

Lender approved exception to allow disputed collection with XXXXXX to remain without payoff or sufficient additional reserves to cover the balance vs program requirement that disputed accounts must be paid in full.

New construction. Re-established tradelines since discharge of Chapter 7 Bankruptcy on XXXXXX Borrower has been self-employed for the past 9 years as XXXXXX 33% DTI < 43% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-09): Client has elected to waive this exception based on the compensating factors.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902126

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow transfer appraisal made subject to with a 1004d (completion report) vs program requirement that transfer appraisals must be made as-is.

New construction. Re-established tradelines since discharge of Chapter 7 Bankruptcy on XXXXXX Borrower has been self-employed for the past 9 years as XXXXXX 33% DTI < 43% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-09): Client has elected to waive this exception based on the compensating factors.

08/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902127

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Reviewer Comment (2019-08-22): Corrected usability factor resulting in DTI adjustment.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902127

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.54323% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Reviewer Comment (2019-08-22): Corrected usability factor resulting in DTI adjustment.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902127

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowners Insurance Included In Escrow

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXXincorrectly disclosed whether Homeowners Insurance is included in escrow.

Section G of the final CD does not reflect any escrows for Homeowners Insurance.

Reviewer Comment (2019-08-14): CD reflect "No" for Homeowner's Insurance in escrow Buyer Comment (2019-08-13): There is no Home Owners Insurance This is a Condo. Master Policy provided for review

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

207902127

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Bank statement income was lower than the income calculated at origination.  Addition items were deducted from total deposits that were not deducted per the worksheet in file.

Reviewer Comment (2019-08-22): Corrected usability factor resulting in DTI adjustment.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902127

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

DTI exceeds guidelines.

Reviewer Comment (2019-08-22): Corrected usability factor resulting in DTI adjustment.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902128

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing the CDA or ARR as required.

Reviewer Comment (2019-08-13): AMC received the CDA dated 7/XX19 for the subject property. Buyer Comment (2019-08-13): CDA uploaded.

08/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207902128

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207902128

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

Initial Escrow disclosure reflects an initial deposit of $1,759.27 yet the CD reflects an amount of $13,461.84.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207902128

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Annual HOA dues per appraiser and Sales Contract reflects an amount of $2,500 yet the final CD shows $2,508.

Reviewer Comment (2019-08-14): AMC received PCCD correcting non escrowed property costs and LOE. Exception Cured. Buyer Comment (2019-08-13): PCCD/LOX/Label uploaded

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207902128

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing Bank Statements used for income qualifications.

Reviewer Comment (2019-08-14): 12 months statements provided for income calculations. Buyer Comment (2019-08-13): XXXXXXC bank statements uploaded

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207902128

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD did not reflect an amount by which the fees exceeded the legal limit.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207902128

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $429.80 exceeds tolerance of $50.00.  Insufficient or no cure was provided to the borrower.

Initial LE reflected a Credit Report Fee of $50 yet the final CD shows a charge of $429.80 without a cure to the borrower.

Reviewer Comment (2019-08-14): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared. Buyer Comment (2019-08-13): PCCD/LOX/Refund/label uploaded.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207902128

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Guideline Requirement: Documented income duration  did not support the minimum guideline required duration.

Borrower's ownership percentage of 15.706% is less than minimum of 25% required per guidelines.  Approved Lender Exception in file.

No public records Borrower has owned 15.706% of XXXXXX employment stability for 13 years in the XXXXXX DTI is 21.79841%, 28.20159% < program max of 50% Credit score is 705, 45 points > program requirement of 640 LTV is 80%, 5% < program max of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-12): Client has elected to waive this exception based on compensating factors.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207902128

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Missing statement XXXXXX  for $300,458.87 no statements provided.

Reviewer Comment (2019-08-14): 2 months statement provided. Buyer Comment (2019-08-13): Uploaded 2 months XXXXXX banks statements and LOE for large deposit.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207902128

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

no assets provided missing verification of xxx xxx for $300,458.87.

Reviewer Comment (2019-08-14): 2 months statement provided. Verified reserves of 4.84 months. Buyer Comment (2019-08-13): Uploaded 2 months XXXXXX banks statements and LOE for large deposit.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207902128

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $429.80 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2019-08-14): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207902129

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Missing Document: Asset Documentation not provided

Missing July 31, XX (business) Asset Statement w/XXXXXX as well as transaction history to fill gap between XXXXXX to  XXXXXX for assets w/XXXXXX

Reviewer Comment (2019-08-15): Updated available assets. Buyer Comment (2019-08-14): Please see Revised 1003-1008 and XXXXXX JUNE statement  -Per the revised 1003-1008, the $125,000 transfer on 7/25 from the borrower business account has been deducted leaving a balance of $72,004.25 for this account, on the same June XX business statement savings account balance is $1029.22 when added to the $125,000 transfer to personal account results in assets of $198,033.47. A transaction history for the borrower's personal account from 7/17 through 7/25 is not needed as we are only using assets from  the $125,000 transfer on 7/XXXX Reviewer Comment (2019-08-14): July XX XXXXXX XXXXXX statement provided. Missing XXXXXX XXXXXX transaction history from XXXXXX to XXXXXX. Pending transaction receipt shows the available balance for XXXXXX is $126,350.34 with an online transfer from business account. Most recent business account statement dated XXXXXX reflects a balance of $122,046.12. Funds are being counted multiple times. Once in the personal account for July and again in the business account as of June. Review assets for reserve requirement of 6 months. Condition remains. Reviewer Comment (2019-08-14): Missing XXXXXX #1530 transaction history from XXXXXX to XXXXXX. Pending transaction receipt shows the available balance for #1530 is $126,350.34 with an online transfer from business account. Most recent business account statement dated XXXXXX reflects a balance of $122,046.12. Condition for transaction history remains. Buyer Comment (2019-08-13): Transaction history from 7/17-7/25 is not material as the balance of borrower's personal account on 7/17 was $1177.54. Using just the $125,000 online transfer from the borrower's business account for this account still provides sufficient reserves for the transaction as the Final CD reflects that CTC was only $88,486.46; please use only the balance transfer amount of $125,000 for this account

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902129

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902129

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow down payment ($25,000) paid from borrowers business funds vs. program requirement to transfer business funds to borrowers personal account for down payment and or closing costs.

Re-established tradelines paid as agreed since discharge of chapter 7 BK XXXXXX 23.36363% DTI on this Alt documentation loan < 43% guideline max - 19.63637% below program guideline maximum Borrower has been self-employed for the past 8 years as XXXXXX FICO 682, 2 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-12): Client has elected to waive this exception based on compensating factors.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902129

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: Closing Disclosure is incomplete

Seller's CD incomplete for date issued

Reviewer Comment (2019-08-14): Completed Seller CD provided. Buyer Comment (2019-08-13): Please see Executed Seller CD

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902129

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___

July XX Business bank statement used for income analysis missing from file

Reviewer Comment (2019-08-14): July XX XXXXXX XXXXXX statement provided. Buyer Comment (2019-08-13): Please see XXXXXX JULY XX

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902129

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902130

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing LO Compensation Disclosure

Buyer Comment (2019-08-14): XXXXXX has elected to waive this exception.

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902130

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Compliance Engine Required from Mavent or ComplianceEase. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-08-14): AMC received the Mavent compliance report dated 8/1/19 on consummation date with a TILA/RESPA Warning, High Costs Warning, HPML Alert, Pass for state. Buyer Comment (2019-08-14): Uploaded For Review- Mavent Report

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902132

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Guarantor Agreement not provided

Missing copy of the Guaranty executed by the owner of the corporation. Loan closed under XXXXXX

Reviewer Comment (2019-08-23): Signed Guaranty Agreement provided

08/23/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Debt Consolidation

D

B

D

A

B

B

A

A

N/A

N/A

No

207902132

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Buyer Comment (2019-08-22): XXXXXX has elected to waive

08/22/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Debt Consolidation

D

B

D

A

B

B

A

A

N/A

N/A

No

207902133

XXXXXX

XXXXXX

Credit

System

General

Valuation address does not match Note address.

-

City on Note reflects xxx vs. city on document listed as xxxx.

Reviewer Comment (2019-08-14): Agree with lender. Per USPS.com, addresses are one and the same. Buyer Comment (2019-08-13): XXXXXX is in XXXXXX

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902133

XXXXXX

XXXXXX

Credit

System

General

Flood Certificate Subject Address does not match Note address.

City on Note reflects XXXX vs. city on document listed as XXXX.

Reviewer Comment (2019-08-14): Agree with lender. Per USPS.com, addresses are one and the same.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902133

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insurance address does not match Note address.

City on Note reflects xxxx vs. city on document listed as xxxx

Reviewer Comment (2019-08-14): Agree with lender. Per USPS.com, addresses are one and the same.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902133

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-14): waive

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902133

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Buyer Comment (2019-08-14): waive

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902133

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-14): waive

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902133

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - S-Corp Test

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status using reasonably reliable third-party records.

Missing current third party verification of borrower's business.

Reviewer Comment (2019-08-15): Third party documentation provided. Reviewer Comment (2019-08-14): Per FNMA, lender must verify the existence of the borrower's business  from a third party, such as a CPA, regulatory agency, or the applicable licensing bureau, if possible; or by verifying a phone listing and address for the borrower's business using a telephone book, the Internet, or directory assistance. Buyer Comment (2019-08-13): business bank statement and tax returns are in file

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902133

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Missing current third party verification of borrower's business causing an ATR fail.

Reviewer Comment (2019-08-15): Third party documentation provided. Reviewer Comment (2019-08-14): Per FNMA, lender must verify the existence of the borrower's business  from a third party, such as a CPA, regulatory agency, or the applicable licensing bureau, if possible; or by verifying a phone listing and address for the borrower's business using a telephone book, the Internet, or directory assistance. Buyer Comment (2019-08-13): business bank statement and tax returns are in file

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902133

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Missing current third party verification of borrower's business.

Reviewer Comment (2019-08-15): Third party documentation provided.

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902133

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - S-Corp Test

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status using reasonably reliable third-party records.

Missing current third party verification of borrower's business.

Reviewer Comment (2019-08-15): Third party documentation provided. Buyer Comment (2019-08-15): Fraud Report reflects borrowers self employment is xxxx Buyer Comment (2019-08-15): Tax Returns have letter from accountant attached Reviewer Comment (2019-08-14): Per FNMA, lender must verify the existence of the borrower's business  from a third party, such as a CPA, regulatory agency, or the applicable licensing bureau, if possible; or by verifying a phone listing and address for the borrower's business using a telephone book, the Internet, or directory assistance. Buyer Comment (2019-08-13): business bank statement and tax returns are in file

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902134

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 8.24170% is in excess of allowable threshold of Prime Mortgage Market Rate 3.48000% + 1.75%, or 5.23000%.  Compliant SubPrime Loan.

Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception.

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902135

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Reviewer Comment (2019-08-13): Client has elected to waive this exception. Buyer Comment (2019-08-13): XXXXXX has elected to waive this exception

08/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902135

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Missing accepted sales contact and signed final CD/HUD from sale of prior primary residence in the amount of $xxxx

Reviewer Comment (2019-08-14): HUD from sale of prior primary residence provided. Buyer Comment (2019-08-13): HUD 1 for sell of Primary

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902135

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrower has been self-employed for 14 months vs program minimum requirement of two full years of self-employment.

No public records Co-borrower has been employed as a XXXXXX for the past 12 years. Borrower has been in the same line of work  (XXXXXX) for the past 8 years. Credit score is 699, 19 points > program requirement of 680

Originator Pre-Close Originator Originator Pre-Close

Reviewer Comment (2019-08-12): Client has elected to waive this exception based on compensating factors.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902135

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Missing accepted sales contact and signed final CD/HUD from sale of prior primary residence in the amount of $xxxxx

Reviewer Comment (2019-08-14): HUD from sale of prior primary residence provided.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902137

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided a copy of the LO Compensation disclosure at time of application.

Buyer Comment (2019-08-14): waive

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902137

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on XXXXXX disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table.

Calculated Cash to Close amount listed on page 1 and page 3 of the final CD reflects an amount of $68,025.86 yet the Summaries of Transactions shows $67,942.09.The difference stems from debts paid off at closing totaling $83.77

Buyer Comment (2019-08-16): waive

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902137

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD does not reflect an amount by which the fees exceed the legal limit.

Reviewer Comment (2019-08-15): Tolerance exceptions are addressed. Exception Cleared.

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902137

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $125.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $125.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. The provider of this service was listed on the settlement service providers disclosure

Reviewer Comment (2019-08-15): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared.

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902137

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $125.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

Reviewer Comment (2019-08-15): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902138

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Loan Estimate not provided to borrower within 3 days of application  loan estimate provided without prior borrowers consent to receive disclosures electronically/

Reviewer Comment (2019-08-22): E-consent provided Buyer Comment (2019-08-21): Docusign Econsent provided

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902138

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on XXXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.

Loan estimate provided electronically prior to borrowers consent Disclosure will not be used for tolerance purposes.

Reviewer Comment (2019-08-22): E-consent provided Buyer Comment (2019-08-21): Econsent provided

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902138

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-08-22): CPA letter provided for available business funds to be used fro closing funds and reserves. Buyer Comment (2019-08-21): CPA letter provided for available business funds - total available funds exceed guideline minimum for closing & reserves - please clear

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

207902139

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-16): Final title provided. Buyer Comment (2019-08-15): Uploaded For Review-Title Policy

08/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

A

B

A

A

A

A

A

Non QM

Non QM

No

207902139

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Reviewer Comment (2019-08-16): Final title provided.

08/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

A

B

A

A

A

A

A

Non QM

Non QM

No

207902140

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing the CDA or ARR as required.

Reviewer Comment (2019-08-16): Desk review provided

08/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

B

B

C

A

Non QM

Non QM

No

207902140

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Greater than 3 Year ARM Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.30630% is in excess of allowable threshold of Prime Mortgage Market Rate 3.47000% + 1.75%, or 5.22000%.  Compliant SubPrime Loan.

Buyer Comment (2019-08-14): XXXXXX has elected to waive

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

B

B

C

A

Non QM

Non QM

No

207902140

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

The final revised loan estimate and the initial closing disclosure were both electronically disclosed on XXXXXX

Buyer Comment (2019-08-14): XXXXXX has elected to waive

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

A

A

B

B

C

A

Non QM

Non QM

No

207902140

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Verified, Provided XXXX19

Buyer Comment (2019-08-14): XXXXXX has elected to waive

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

B

B

C

A

Non QM

Non QM

No

207902141

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow the inclusion of rental income documented with a lease only vs program requirement for copies of all leases and 3 months documented rent receipts.

Borrower has been employed for the past 19 years as a XXXXXX Excellent mortgage history all paid as agreed since earliest inception date of XXXXXX. Perfect credit history all paid as agreed since earliest inception date of XXXXXX. No public records. 20.11 months reserves > 4 months guideline minimum (3 months required plus 1 month for additional investment property owned) 781 representative FICO score > 640 guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-14): Client has elected to waive this exception based on compensating factors.

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902141

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Paid To party cannot be determined on the Closing Disclosure. For compliance testing purposes, Paid To of Lender will be considered in lieu of UTD.

- ___

Fee listed as to be determined on the initial and final CD.

Buyer Comment (2019-08-15): XXXXXX has elected to waive

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

207902141

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section C Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Closing Disclosure provided on XXXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Shop For.

Notary fee listed with service provider as To Be Determined

Buyer Comment (2019-08-15): XXXXXX has elected to waive

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good Faith Redisclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

207902142

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Origination Compensation disclosure not provided. Unable to determine if compensation was based on a term of the transaction

Buyer Comment (2019-08-14): XXXXXX has elected to waive this exception.

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902143

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender authorized exception to allow all down payment and closing costs paid from borrowers business account vs. program requirement to transfer business funds used for closing costs and down payment to a personal account owned by the borrower

Tradelines paid as agreed with one isolated 30 day revolving late XXXXXX, no public records. 38.58169% DTI on this Alt documentation loan < 43% guideline max - 4.41831% below program guideline maximum Borrower has been self-employed for the past 25 years a XXXXXX Credit score is 734, 54 points > program requirement of 680

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-15): Client has elected to waive this exception based on compensating factors.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902143

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Missing Document: Gift Letter not provided

Gift received in amount of $20,000 on XXXX19 deposited into XXXXXXaccount no gift letter provided.

Reviewer Comment (2019-08-19): Gift letter provided Reviewer Comment (2019-08-16): Gift letter provided is not legible.

08/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902143

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-15): XXXXXX has elected to waive

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902143

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Documented qualifying Assets for Closing of  ___ is less than Cash From Borrower ___.

Missing bank statement with assets of $36,832.07 per final 1003

Reviewer Comment (2019-08-20): Updated final 1003 provided. Reviewer Comment (2019-08-16): XXXXXX XXXXXX xxxxwith a balance of $36,832.07 was not provided.

08/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902144

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $519.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing.

Appraisal Fee Amount of $519.00 exceeds tolerance of $500.00. Sufficient cure was provided to the borrower at closing

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

A

C

A

A

A

A

A

Non QM

Non QM

Yes

207902144

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-08-16): Updated assets to satisfy funds to close. Buyer Comment (2019-08-16): Please see XXXXXX reflecting balance of $100,108.99 which is inclusive of $78,806 in Gift Funds, EMD WIRE $xxxx, please see XXXXXX xxxx borrower 25% owner $9,047.25

08/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

The final CD disclosed the Amount of Non-Escrowed Property Costs over Year 1 as $2,821.83 on page 4; however the monthly HOA is $256, which is $3,072 per year.

Reviewer Comment (2019-08-22): Per sale contract addendum unit monthly maintenance fee is $256.53.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Reviewer Comment (2019-08-20): AMC received the disclosure summary with document date provided 6/XX19.

08/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Reviewer Comment (2019-08-20): AMC received the disclosure summary with document date provided 6/XX19.

08/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Reviewer Comment (2019-08-20): AMC received the disclosure summary with proof of document provided 6/XX19.

08/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Missing evidence disclosure was provided to the borrower within 3 business days of application.

Reviewer Comment (2019-08-21): AMC received SSPL. Exception Cleared.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $2,281.00 exceeds tolerance of $2,070.00 plus 10% or $2,277.00.  Insufficient or no cure was provided to the borrower.

File is missing service provider list. Unable to determine tolerance cure.

Reviewer Comment (2019-08-21): AMC received SSPL. Exception Cleared.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902145

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Compliance Engine Required from Mavent or ComplianceEase. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-08-20): AMC received the Mavent dated 8/7/19.

08/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

File is missing service provider list. Unable to determine tolerance cure.

Reviewer Comment (2019-08-21): Tolerance exceptions are addressed. Exception Cleared.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Compliant Test

TIL variable rate disclosure: ARM loan program disclosure does not match terms of loan.

actual document not provide to determine if arm loan terms were disclosed and matched program.

Reviewer Comment (2019-08-22): AMC received the disclosure dated 6/XX19 with arm terms disclosed.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

Disclosure dated XXXX19 not within 3 days of application.

Reviewer Comment (2019-08-22): Loan was disclosed at application X/X/XX as a foxed rate - per COC and LE dated 6/XX19 program change occurred to a ARM - disclosure dated 6/XX19 within 3 days of change.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902145

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

High Cost Indicator Test

Loan does not exceed any high cost thresholds, however, documentation indicating loan was originated as a high cost loan found in file.

Mavent report dated XXXX19 reflects as a high cost fail.

Buyer Comment (2019-08-22): XXXXXX has elected to waive

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902146

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-16): waive

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902146

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2019-08-17): Evidence of earlier receipt was provided.

08/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902146

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Representative FICO score of ___ is less than Guideline representative FICO score of ___.

Lender approved exception to allow FICO of 677 vs program requirement of 680

VOR reflects paid as agreed for 12 months.  One closed mortgage reflects, paid as agreed.  No public records Borrower has been self-employed for the past 2.6 years as XXXXXX DTI is 19% < program maximum of 43% 4.52 months reserves > program requirement of 3 months

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-15): Client has elected to waive this exception based on compensating factors.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902146

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Business funds used for closing. Missing letter from CPA or professional tax preparer stating that the withdrawal of funds will not have a negative impact on the business.

Reviewer Comment (2019-08-19): Guidelines section 7.1, item 4, paragraph 1 states that the requirement for a statement from the CPA/tax preparer is waived if the LTV ratio is 90% or less. Buyer Comment (2019-08-19): We don't need an CPA letter for use of business funds since the LTV/CLTV is 90%

08/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902146

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure X/X/XX 12:00:00 AM was received.

Final LE issued on XXXX19 was received on the same date as the initial CD was issued.

Buyer Comment (2019-08-19): waive

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902147

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Lender granted an exception allowing the higher LTV. See Doc #0009.

One open mortgage reflects 0x30 since inception XXXXXX. Three closed mortgages reflect paid as agreed and no public records. Perfect credit history since inception of earliest account opened XXXXXX Borrower has been XXXXXX for the past 20 years and in the same line of business for the past 25 years. DTI is 41.81867% which is 8.18133% < the program max of 50%. 791 representative FICO score > 700 guideline minimum -91 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-15): Client has elected to waive this exception based on compensating factors.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902147

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Combined loan to value discrepancy.

Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___.

Lender granted an exception allowing the higher CLTV. See Doc #0009.

One open mortgage reflects 0x30 since inception XXXXXX. Three closed mortgages reflect paid as agreed and no public records. Perfect credit history since inception of earliest account opened XXXXXX Borrower has been XXXXXX for the past 20 years and in the same line of business for the past 25 years. DTI is 41.81867% which is 8.18133% < the program max of 50%. 791 representative FICO score > 700 guideline minimum -91 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-15): Client has elected to waive this exception based on compensating factors.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902147

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Disclosure is missing

Buyer Comment (2019-08-15): XXXXXX has elected to waive this exception.

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902147

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $495.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Fees entered as reported

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

207902148

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-16): XXXXXX has elected to waive this exception.

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902148

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Guideline Requirement: Documented income duration  did not support the minimum guideline required duration.

Allow Spousal support finalized XXXX19 using document of divorce decree only vs. program requirement of a minimum of copy of divorce plus 6 months evidence of receipt.  Approved Lender Exception in file.

Only 1x30 on entire credit report on a mortgage in XXXXXX, going back to earliest account inception date of XXXXXX2 and no public records. Subject is a new construction. Borrower has been in the same line of work (XXXXXX) for over 2 years. 148.53 months reserves 142.53 months > program requirement of 6 months. Credit score is 786, 106 points> program requirement of 680. LTV is 64.73%, 15.27% < program maximum of 80%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-16): Client elected to waive this exception based on compensating factors.

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902148

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final CD shows a closing date of XXXX19 yet Notary Date on Security Instrument confirms closing date of XXXX19.

Buyer Comment (2019-08-16): XXXXXX has elected to waive this exception.

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

207902150

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Loan amount of XXXXXX  exceeds max of $3,000,000.  Approved Lender Exception in file.

Purchase price is XXXXXX.  XXXX style home in XXXXXX and quite rural like atmosphere among many high end homes.. All tradelines show paid as agreed since earliest account inception date of 8/1998. Borrower has been self-employed for the past  13 years as XXXXXX Credit score is 731, 31 points > program requirement of 700.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-16): Client has elected to waive this exception based on compensating factors.

08/16/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

B

B

A

A

N/A

N/A

No

207902150

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

5.40 months of reserves is insufficient to cover minimum of 12 months required per guidelines.

Purchase price is XXXXXX.  XXXX style home in XXXXXX and quite rural like atmosphere among many high end homes.. All tradelines show paid as agreed since earliest account inception date of 8/1998. Borrower has been self-employed for the past  13 years as XXXXXX Credit score is 731, 31 points > program requirement of 700.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-29): Client elects to waive the exception with verified compensation factors.

08/29/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

B

B

A

A

N/A

N/A

No

207902150

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Missing evidence the initial appraisal dated XXXX19 was provided to the borrower.

Buyer Comment (2019-08-28): XXXXXX has elected to waive

08/28/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

B

B

A

A

N/A

N/A

No

207902151

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

High Cost Indicator Test

Loan does not exceed any high cost thresholds, however, documentation indicating loan was originated as a high cost loan found in file.

The compliance report in file indicates a high cost failure.

Buyer Comment (2019-08-21): waive

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902151

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-21): waive

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902151

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. $0.00

Reviewer Comment (2019-08-21): Attestation provided by lender that the $75 Processing Fee on the LE's was re-named to $75 Assignment Fee on the CD's.  Fees are one in the same

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902151

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Assignment Fee.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Final disclosure reflects a fee of $75.00 paid for Title-Assignment to a vendor listed on the Settlement Providers List that was not previously disclosed

Reviewer Comment (2019-08-21): Attestation provided by lender that the $75 Processing Fee on the LE's was re-named to $75 Assignment Fee on the CD's.  Fees are one in the same Buyer Comment (2019-08-20): Fee was disclosed on LE as Title Processing Fee and renamed Title Assignment on final CD

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902151

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Fee Terminology

TILA-RESPA Integrated Disclosure: Final Closing Disclosure provided on XXXXXX did not use the same fee terminology as the Loan Estimate.

LE's listed $75 Processing Fee.  Fee name changed to $75 Assignment Fee on the CD's

Buyer Comment (2019-08-21): waive

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902152

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-20): XXXXXX has elected t waive this exception

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902152

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $495.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

08/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207902152

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Lender acknowledge exception to allow 78% LTV in file

Perfect credit and mortgage history always paid as agreed with no public records. VOM confirms no late payments since inception on the first mortgage XXXXXX (24 months ago) and the HELOC paid on time since inception XXXXXX (21 months ago) Self-employed for the past 20 years in XXXXXX Credit score is 747, 47 points > program requirement of 700 Not a rate and term refinance due to paying off a HELOC with recent draws, but all cash out proceeds are to repay existing mortgages (1st and Heloc)

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-16): Client has elected to waive this exception based on compensating factors.

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902152

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Combined loan to value discrepancy.

Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___.

Lender acknowledge exception to allow 78% LTV in file

Perfect credit and mortgage history always paid as agreed with no public records. VOM confirms no late payments since inception on the first mortgage XXXXXX (24 months ago) and the HELOC paid on time since inception XXXXXX (21 months ago) Self-employed for the past 20 years in XXXXXX Credit score is 747, 47 points > program requirement of 700 Not a rate and term refinance due to paying off a HELOC with recent draws, but all cash out proceeds are to repay existing mortgages (1st and Heloc)

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-16): Client has elected to waive this exception based on compensating factors.

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902152

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

7.86 months of reserves is less than 12 months required per guidelines.  Approved Lender Exception in file for 4 month - revised exception required.

Perfect credit and mortgage history always paid as agreed with no public records. VOM confirms no late payments since inception on the first mortgage XXXXXX (24 months ago) and the HELOC paid on time since inception XXXXXX (21 months ago) Self-employed for the past 20 years in XXXXXX Credit score is 747, 47 points > program requirement of 700 Not a rate and term refinance due to paying off a HELOC with recent draws, but all cash out proceeds are to repay existing mortgages (1st and Heloc)

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-23): Client elects to waive the exception with verified compensation factors. Buyer Comment (2019-08-23): Uploaded For Review-Exception Approval

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902154

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Reviewer Comment (2019-08-22): AMC received the completed and signed ATR attestation. Buyer Comment (2019-08-22): ATR for review

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902154

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-22): AMC received the updated preliminary with proposed insured liability of $680,000. Buyer Comment (2019-08-22): ATR for review, Corrected Title

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902154

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Reviewer Comment (2019-08-28): AMC received the revised HOI with mortgagee clause including ISAOA. Buyer Comment (2019-08-28): HOI with dwelling at $500K for review Reviewer Comment (2019-08-27): HOI policy provided has the wrong dwelling amount. Provide policy with dwelling coverage of $500,000.00 and mortgagee clause corrected. Buyer Comment (2019-08-26): Corrected HOI for review

08/28/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902155

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

A first lien purchase transaction did not disclose any Seller paid fees/charges on page 2.

Reviewer Comment (2019-08-21): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-08-20): Please see PCCD, LOX, LABEL

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

A

A

C

A

A

A

Non QM

Non QM

Yes

207902156

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-19): XXXXXX has elected to waive this exception.

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902156

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow EMD and additional down payment funds to come from business account, program requires funds to be moved from business to personal account

No public records. Borrower has been XXXXXXfor the past 6 years. Reserves are 5 months, 2 months > program requirement of 3 months. DTI is 9.50200%, 40.498% < program maximum of 50%. Credit score is 654, 14 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-19): Client has elected to waive this exception based on compensating factors.

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902157

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.40510% or Final Disclosure APR of 7.45700% is in excess of allowable threshold of APOR 4.26% + 1.5%, or 5.76000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-08-21): Title Commitment shows that the property was acquired by the seller through foreclosure on XXXXXX.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902157

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Flipped Property - Did Not Obtain 2 Appraisals)

TILA HPML Appraisal Rule  (Dodd-Frank 2014): Flipped Property - Creditor did not obtain two (2) written appraisals.

Purchase price of $XXXXXX > 10% of the purchase price by the seller of $XXXXXX and property was obtained by the seller within the last 6 months. Two appraisals are required.

Reviewer Comment (2019-08-21): Title Commitment shows that the property was acquired by the seller through foreclosure on XXXXXX. Buyer Comment (2019-08-20): The seller is a bank and the property was a foreclosure.  This is not a flip. Please see contract and appraisers comments.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902157

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided an incorrect amount that the Total Closing Costs exceeded the legal limit

Buyer Comment (2019-08-20): XXXXXX elects to waive this exception.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902157

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $621.00 exceeds tolerance of $596.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $621.00 exceeds tolerance of $596.00.  Missing proof of valid change, insufficient or no cure was provided to the borrower. Loan was locked by the lender on XXXXXX, discount points increased on the XXXXXX loan estimate

Reviewer Comment (2019-08-21): AMC received XXXXXX COC. Exception Cleared. Buyer Comment (2019-08-20): See attached VCOC

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902157

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $316.50 exceeds tolerance of $251.00.  Insufficient or no cure was provided to the borrower.

Endorsement Fee amount of $316.50 exceeds tolerance of $251.00.  Fee was present on early disclosures then was removed. No cure was provided to the borrower

Reviewer Comment (2019-08-21): AMC reviewed exception. The fee is paid to chosen provider. Exception Cleared. Buyer Comment (2019-08-20): Within 10% tolerance threshold.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902157

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Loan File

Missing Document: Hazard Insurance Policy not provided

File contains evidence of insurance only, declaration or policy not present

Reviewer Comment (2019-08-22): Hazard Insurance Policy provided Buyer Comment (2019-08-22): Please see attached Reviewer Comment (2019-08-21): Evidence of insurance provided is missing the policy effective date, policy expiration date, property location and policy number. Buyer Comment (2019-08-20): See attached

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902157

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Paid To party cannot be determined on the Closing Disclosure. For compliance testing purposes, Paid To of Lender will be considered in lieu of UTD.

- ___

Buyer Comment (2019-08-20): XXXXXX elects to waive this exception.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902157

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section C Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Closing Disclosure provided on XXXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Shop For.

Tax cert paid to unable to determine no service provider reflected.

Buyer Comment (2019-08-20): XXXXXX elects to waive this exception.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good Faith Redisclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902158

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Status Test

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

Missing

Reviewer Comment (2019-08-22): ARM Disclosure provided. Buyer Comment (2019-08-21): ARM Disclosure provided

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902158

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

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

Missing

Reviewer Comment (2019-08-20): CHARM booklet provided XXXXXX. Buyer Comment (2019-08-20): Evidence Charm booklet provided to client uploaded

08/20/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

207902160

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

DTI is 51.34% vs. program maximum of 50%.  Approved Lender Exception in file.

762 representative FICO score > 700 guideline minimum - 62 points above guideline minimum Borrower is XXXXXX with 35 years in the same line of work.  Co borrower has been XXXXXX for the past 30 years. Subject mortgage and heloc both reporting 0x30 since inception XXXXXX.  Perfect credit with no late payments dating back to earliest account inception XXXXXX.  No Public Records. Reserves are 26.92 months, 14.92  months > program requirement of 12 months.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-19): Client has elected to waive this exception based on compensating factors.

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902160

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 51.34231% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Loan fails ATR Risk due to DTI of 51.34% exceeding max 50% allowed per guidelines.  Approved Lender Exception in file.

762 representative FICO score > 700 guideline minimum - 62 points above guideline minimum Borrower is XXXXXX with 35 years in the same line of work.  Co borrower has been XXXXXX for the past 30 years. Subject mortgage and heloc both reporting 0x30 since inception XXXXXX.  Perfect credit with no late payments dating back to earliest account inception XXXXXX.  No Public Records. Reserves are 26.92 months, 14.92  months > program requirement of 12 months.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-19): Client has elected to waive this exception based on compensating factors.

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902160

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Loan is considered a cash out refinance due to revolving debt paid off at closing exceeding $2,000.  LTV of 76% exceeds max allowed of 75%.  Lender Exception for excessive LTV was removed.

762 representative FICO score > 700 guideline minimum - 62 points above guideline minimum Borrower is XXXXXX with 35 years in the same line of work.  Co borrower has been XXXXXX for the past 30 years. Subject mortgage and heloc both reporting 0x30 since inception XXXXXX.  Perfect credit with no late payments dating back to earliest account inception XXXXXX.  No Public Records. Reserves are 26.92 months, 14.92  months > program requirement of 12 months.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-23): Client elects to waive the exception with verified compensation factors. Reviewer Comment (2019-08-22): Please correct lender approved exception for current DTI to 51.342%. Reviewer Comment (2019-08-20): Per final CD, paying off additional liabilities other than 1st and 2nd mtg resulting in a Cash-out Refi. Buyer Comment (2019-08-20): This is a Rate and Term. Borrower brought cash in to close

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902160

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Combined loan to value discrepancy.

Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___.

Loan is considered a cash out refinance due to revolving debt paid off at closing exceeding $2,000.  CLTV of 76% exceeds max allowed of 75%.  Lender Exception for excessive LTV was removed.

762 representative FICO score > 700 guideline minimum - 62 points above guideline minimum Borrower is XXXXXX with 35 years in the same line of work.  Co borrower has been XXXXXX for the past 30 years. Subject mortgage and heloc both reporting 0x30 since inception XXXXXX.  Perfect credit with no late payments dating back to earliest account inception XXXXXX.  No Public Records. Reserves are 26.92 months, 14.92  months > program requirement of 12 months.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-23): Client elects to waive the exception with verified compensation factors. Reviewer Comment (2019-08-22): Please correct lender approved exception for current DTI to 51.342%. Reviewer Comment (2019-08-20): Per final CD, paying off additional liabilities other than 1st and 2nd mtg resulting in a Cash-out Refi. Buyer Comment (2019-08-20): This is a Rate and Term. Borrower brought cash in to close

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902161

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to all down payment ($5,000) paid from borrower's business funds vs. program requirement to transfer business funds to borrower's personal account for down payment and or closing costs.

No public records 9.50087% DTI on this Alt documentation loan < 43% guideline max - 33.49913% below program guideline maximum Borrower has been self-employed for the past 2 years as XXXXXX with 7 years in the same profession. Reserves are 42.60 months, 39.60 months > program requirements of 3 months Credit score is 721, 41 points > program requirement of 680

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-20): Client has elected to waive this exception based on compensating factors.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902161

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

Missing additional 30 day statement for XXXXXX used by Lender to qualify.

Reviewer Comment (2019-08-21): Removed account from assets not needed for closing funds or reserves. Buyer Comment (2019-08-21): This account XXXXXX had a prior balance of $133 and is being used to show transfer of business funds needed for closing  as required by guidelines. Please see three deposits from borrower's business account on 7/30 $56500, 7/29 $XX.94, 7/12 $XX.94 7/1 $XX.94

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final CD reflects a closing date of XXXX19 yet borrower signed on XXXX19.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902161

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

Seller's CD did not disclose any Seller paid Fees.

Reviewer Comment (2019-08-28): Letter of Explanation & Corrected Closing Disclosure provided. Buyer Comment (2019-08-27): Please see PCCD, LOE, LABEL Reviewer Comment (2019-08-23): Exception was incorrectly waived. Buyer Comment (2019-08-23): XXXXXX has elected to waive this exception

08/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902162

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception for borrower self employed for 15 months, program requires 24

Perfect credit and no public records.  Mortgage history with 1 active mortgage paid as agreed since inception XXXXXX Reserves are 26.65 months, 23.65 months > program requirement of 3 months ($5,609.40) DTI is 42.86%, 7.14% < program maximum of 50.00% Borrower has 8 years in XXXX and has been self-employed for the past 15 months as owner of XXXXXX which XXXXXX in the XXXXXX area. Credit score is XXX, 44 point > program requirement of 700. LTV is 71.029, 13.971% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-19): Client has elected to waive this exception based on compensating factors.

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902163

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-21): AMC received the title supplement for the subject with proposed loan amount coverage of XXXXXX Buyer Comment (2019-08-21): Revised Title provided

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

A

B

B

A

A

Non QM

Non QM

No

207902163

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-20): XXXXXX has elected to waive this exception.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

A

B

B

A

A

Non QM

Non QM

No

207902163

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $60.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Cure of $60 provided on final CD

08/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

B

A

B

B

A

A

Non QM

Non QM

Yes

207902163

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Page 4 of final CD did not disclose a demand feature.

Buyer Comment (2019-08-20): XXXXXX has elected to waive this exception.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

A

B

B

A

A

Non QM

Non QM

Yes

207902164

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Note reflects assumption verbiage yet final CD indicates assumptions not allowed.

Buyer Comment (2019-08-21): XXXXXX has elected to waive

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902164

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

12 month premium listed of $2,211.38 in section F of prepaids included a 1 time $199 fee at time of issuance yet actual annual premium is $2,012.28 per policy.

Buyer Comment (2019-08-21): XXXXXX has elected to waive

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902164

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

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

Home Loan Toolkit provided on XXXX19 which is not within 3 business days of initial application date of XXXX19.

Reviewer Comment (2019-08-21): Initial disclosure summary provided.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902164

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Evidence of earlier borrower receipt was not found in file.

Reviewer Comment (2019-08-22): New exception populated. Exception Cleared. Reviewer Comment (2019-08-22): AMC received XX26 CD with a snippet of a CD signature dated XXXX19. Please provide the entire CD that was signed for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902164

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

CHARM Booklet provided to the borrower on XXXX19 which is not within 3 business days of the initial application date of XXXX19.

Reviewer Comment (2019-08-21): Initial disclosure summary provided.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902164

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

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

Disclosure dated XXXX19

Reviewer Comment (2019-08-21): Initial disclosure summary provided.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902164

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

AMC received XX26 CD with a snippet of a CD signature dated XXXX19. Please provide the entire CD that was signed for review.

Reviewer Comment (2019-08-22): AMC received XX26 signed the same day. Exception Cleared.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902165

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for homeowner's insurance under Prepaids.

Line 1 of Section F, number of months is blank.

Buyer Comment (2019-08-20): XXXXXX has elected to waive this exception.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207902165

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $750.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing.

Appraisal Fee Amount of $750.00 exceeds tolerance of $650.00. Sufficient cure was provided to the borrower

08/20/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207902165

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure X/X/XX 12:00:00 AM was received.

LE dated XXXXXX received on XXXXXX, which is the same date of initial CD dated XXXXXX

Buyer Comment (2019-08-20): XXXXXX has elected to waive this exception.

08/20/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Reviewer Comment (2019-08-22): Appraisal provided Buyer Comment (2019-08-21): Appraisal uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Appraisal is missing; not provided.

Reviewer Comment (2019-08-22): Appraisal with effective date of XXXXXX provided Buyer Comment (2019-08-21): Appraisal uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Appraisal is missing; not provided.

Reviewer Comment (2019-08-22): Appraisal with effective date of XXXXXX provided Buyer Comment (2019-08-21): Appraisal uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-08-22): AMC received the appraisal receipt dated 7/XX19.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.17230% or Final Disclosure APR of 8.23400% is in excess of allowable threshold of APOR 4.30% + 1.5%, or 5.80000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-08-22): AMC received the appraisal receipt dated 7/XX19. Reviewer Comment (2019-08-22): Appraisal with effective date of XXXXXX provided Buyer Comment (2019-08-21): Appraisal uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Appraisal is missing; not provided.

Reviewer Comment (2019-08-22): Appraisal provided Buyer Comment (2019-08-21): Appraisal uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Appraisal is missing; not provided.

Reviewer Comment (2019-08-22): Appraisal provided Buyer Comment (2019-08-21): Appraisal uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Appraisal is missing; not provided.

Reviewer Comment (2019-08-22): Appraisal provided Buyer Comment (2019-08-21): Appraisal uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Appraisal Flipped Property Missing Information

Last Sales Price or Last Sales Date from the Primary Valuation or Contract Sales Price or Contract Sales Date are missing. Unable to determine compliance with TIL HPML Flipped Property Requirements.

Appraisal is missing; not provided.

Reviewer Comment (2019-08-22): Appraisal provided Buyer Comment (2019-08-21): Appraisal uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section B Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Not Shop For section.

Title - Lender's Title Insurance paid to party was left blank.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good Faith Redisclosure

D

B

D

A

C

B

C

A

Non QM

Non QM

Yes

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Paid To party cannot be determined on the Closing Disclosure. For compliance testing purposes, Paid To of Lender will be considered in lieu of UTD.

- ___

Title - Lender's Title Insurance paid to party was left blank.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

C

A

Non QM

Non QM

Yes

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Buyer Comment (2019-08-22): XXXXXX has elected to waive this exception.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-08-22): AMC received the appraisal receipt dated 7/XX19. Buyer Comment (2019-08-22): Appraisal Receipt confirmation uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902166

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-08-23): XXXXXX has elected to waive this exception.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902167

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902167

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing CPAletter/ownership % for borrower co-borrower of XXXXXX

Reviewer Comment (2019-08-22): Agree with lender. Buyer Comment (2019-08-21): Articles of Incorporation state under#4: the corporation has one or more additional incorporators and the name and mailing address of each additional incorporator are stated in an attachment. The attached shows the borrower as the additional incorporator

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Reviewer Comment (2019-08-22): Appraisal provided. Buyer Comment (2019-08-21): Appraisal Report uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Appraisal is missing from the file

Reviewer Comment (2019-08-22): Appraisal provided. Buyer Comment (2019-08-21): Appraisal report uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2019-08-22): Appraisal provided. Buyer Comment (2019-08-21): Appraisal report uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Reviewer Comment (2019-08-23): XXXXXX Mortgage Statement provided. Buyer Comment (2019-08-22): Statement attached is from XXXXXX for XXXXXX. reflects loan is escrowed

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 50.75831% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Loan failed ATR Risk due to DTI exceeding max allowed of 50% per guides.  Approved Lender Exception in file.

Perfect credit history with never a late payment and no public records Borrower has been XXXXXX for the past 9 years 7.86 months of reserves, 1.86 months > program requirement of 6 months Credit score is 794, 154 points > program requirement of 640 LTV is 56.67%, 28.33% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-21): Client has elected to waive this exception based on compensating factors.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.  Amount to cure is $50.25.  No evidence in file that cure was provided to Borrower.

Reviewer Comment (2019-08-23): Tolerance exceptions are addressed. Exception Cleared. Buyer Comment (2019-08-22): uploaded COC

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

D

B

D

B

C

B

C

A

Non QM

Non QM

Yes

207902168

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. Actual closing date is XXXX19

Reviewer Comment (2019-08-23): AMC received disclosure tracking indicating the initial CD was received the same day. Exception Cleared.

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

No Defined Cure

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXX exceeds tolerance of $4,200.00.  Insufficient or no cure was provided to the borrower.

Mortgage Broker Fee increased from $4,200.00  $4,250.25 without a valid change circumstance. Tolerance exceeded.

Reviewer Comment (2019-08-23): AMC received XX10 COC. Exception Cleared.

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

D

B

D

B

C

B

C

A

Non QM

Non QM

Yes

207902168

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender acknowledged exception for DTI > 50 in file

Perfect credit history with never a late payment and no public records Borrower has been XXXXXX for the past 9 years 7.86 months of reserves, 1.86 months > program requirement of 6 months Credit score is 794, 154 points > program requirement of 640 LTV is 56.67%, 28.33% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-21): Client has elected to waive this exception based on compensating factors.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Title Commitment amount of $282,000 is insufficient to cover loan amount of XXXXXX

Reviewer Comment (2019-08-26): Title Policy with correct amount of $xxxx provided.

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902168

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

.

Reviewer Comment (2019-08-22): Effective date is XXXXXX

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

D

B

D

B

C

B

C

A

Non QM

Non QM

No

207902169

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation disclosure not in file. Unable to determine if the compensation was based on a term of the transaction

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902170

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Allow the use of appraisal report with appraisal transfer letter that does not meet all XXXXXX Mortgage transfer requirement verbiage Lender will not provide anything further than what is currently documented.  Letter is missing borrower name, complete subject property address, XXXXXX  address vs. program requirement that the appraisal transfer letter must meet XXXXXX guidelines.  Approved Lender Exception in file.

One open mortgage reflects 0x30 since inception 2XXXXXX.  Four closed mortgages reflect paid as agreed.  Perfect credit history since inception of earliest account opened XXXXXX1.  No public records. Borrower has been self employed for the past 27 years as XXXXXX Credit score is 812, 152 points > program requirement of 660.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-21): Client has elected to waive this exception based on compensating factors.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

B

B

Non QM

Non QM

No

207902170

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. $0.00

Buyer Comment (2019-08-22): XXXXXX elects to waive this exception. SM

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

B

B

Non QM

Non QM

Yes

207902170

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $3,580.50 exceeds tolerance of $2,859.00 plus 10% or $3,144.90.  Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance exceeded. Total amount of $3,580.50 exceeds tolerance of $2,859.00 plus 10% or $3,144.90.

Reviewer Comment (2019-08-23): AMC reviewed exception. Upon further review exception may be cleared. Buyer Comment (2019-08-22): Please be specific as to which fees are out of tolerance and provide cure.

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

B

B

Non QM

Non QM

Yes

207902170

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Reviewer Comment (2019-08-23): Corrected taxes on REO for commercial property. Buyer Comment (2019-08-22): Taxes and insurance were pulled from the tax returns (Schedule E )

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

B

B

Non QM

Non QM

No

207902171

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-22): XXXXXX has elected to waive this exception

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902171

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Reviewer Comment (2019-08-26): Valid COC provided. Reviewer Comment (2019-08-22): Changed Circumstance required in order to address the exception, or PCCD, LOE, proof of delivery would be required. Buyer Comment (2019-08-22): Please see COC LE, SSPL, FINAL CD

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902171

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXX exceeds tolerance of $8,313.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $8,509.41 exceeds tolerance of $8,313.00.  Missing proof of valid change, insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-08-26): Valid COC provided. Reviewer Comment (2019-08-22): Changed Circumstance required in order to address the exception, or PCCD, LOE, proof of delivery would be required. Reviewer Comment (2019-08-22): Cured in error. Reviewer Comment (2019-08-22): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-22): Please see COC LE

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902171

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $670.00 exceeds tolerance of $600.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $670.00 exceeds tolerance of $600.00, a cure of $70.00 was provided for this overage.

Reviewer Comment (2019-08-22): SitusAMC received required documents, exception is cured at closing. Buyer Comment (2019-08-22): Please see Final CD section J reflects $70 lender credit to cure

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902171

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender approved exception for DTI exceeding 50%

No public records. VOR reflects 0x30 since inception XXXXXX Borrower has been self-employed for the past 6 years as XXXXXX Credit score is 643, 3 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-21): Client has elected to waive this exception based on compensating factors.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902171

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.76950% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

No public records. VOR reflects 0x30 since inception XXXXXX Borrower has been self-employed for the past 6 years as XXXXXX Credit score is 643, 3 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-21): Client has elected to waive this exception based on compensating factors.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902171

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow funds for down payment coming from borrower's business account vs program requirement that if funds in a business or brokerage account have not been transferred to the Borrowers personal accounts, such funds may not ne included in down payment and closing costs.

No public records. VOR reflects 0x30 since inception XXXXXX Borrower has been self-employed for the past 6 years as XXXXXX Credit score is 643, 3 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-21): Client has elected to waive this exception based on compensating factors.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902171

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Attorney Review Fee.  Fee Amount of $75.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided.

Reviewer Comment (2019-08-22): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-22): PLease see SSPL reflecting title company of Priority Title; Please see section C reflecting title company is PGP Title - borrower chose their own title company as a result the $75 Title Attorney Fee does not require refund to cure

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902171

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $670.00 exceeds tolerance of $600.00.  Sufficient or excess cure was provided to the borrower at Closing.

Cured at closing

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902172

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Missing the CDA or ARR as required by the guides.

Reviewer Comment (2019-08-22): CDA provided. Buyer Comment (2019-08-21): CDA uploaded for review.

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

B

B

C

A

Non QM

Non QM

No

207902172

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

B

B

C

A

Non QM

Non QM

No

207902172

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Rate Spread Threshold Test Compliant

XXXXXX Rate Spread Home Loan: APR on subject loan of 7.17760% or Final Disclosure APR of 7.25000% is in excess of allowable threshold of APOR 4.30% + 1.5%, or 5.80000%.  Compliant Rate Spread Home Loan.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

B

B

C

A

Non QM

Non QM

No

207902172

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

Section F item 4 number of months is blank.

Buyer Comment (2019-08-21): XXXXXX has elected to waive this exception.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

B

B

C

A

Non QM

Non QM

Yes

207902172

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

lender approved exception for subject property of xx.xx acres vs program maximum of 15

Reserves are 88.73 months, 85.73 months > program requirement of 3 months. No public records. Borrower has been XXXXXX for the past 2.94 years. DTI is 20.50887%, 29.49113% < program maximum of 50.00% Credit score is 751, 111 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-21): Client has elected to waive this exception based on compensating factors.

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

B

B

C

A

Non QM

Non QM

No

207902173

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow Co-Borrower xxxx to qualify with only one credit score vs program requirement of the lower score for Occupying Borrowers with 2 two valid credit scores.

Perfect credit history since inception of earliest account opened XXXXXX. No public records. 41.879% DTI < 50% guideline max 17.73 months reserves > 3 months guideline minimum FICO is 705 > program requirement of 620 47.368% LTV < 85% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-22): Client has elected to waive this exception based on compensating factors.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902174

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-26): waive

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902174

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Seller Credit

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on XXXXXX disclosed a Seller Credit that does not match the Seller Credit from the Calculating Cash to Close table.

Seller credit of $1,300 not disclosed in the calculating cash to close page 3.

Buyer Comment (2019-08-26): waive

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902174

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $52.46 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower at Closing.

Credit report fee increased from $50.00 to $52.46 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure was provided to Borrower

08/22/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902174

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

No cure provided

Buyer Comment (2019-08-26): waive

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902174

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $52.46 exceeds tolerance of $50.00.  Insufficient or no cure was provided to the borrower.

No COC or cure provided.

Reviewer Comment (2019-08-27): $2.46 cure on final cd Buyer Comment (2019-08-26): $2.46 cure applied on final CD

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902174

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Survey Fee.  Fee Amount of $250.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No COC or cure provided.

Reviewer Comment (2019-08-27): Confirmed $300 survey fee disclosed in section H on initial LE. Moved to section C on final CD Buyer Comment (2019-08-26): $300 survey fee disclosed in section H on initial LE. Moved to section C on final CD

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902175

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Loan Underwriting and Transmittal Summary (1008) / MCAW not provided

Reviewer Comment (2019-08-23): Loan Underwriting and Transmittal Summary (1008) provided

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

207902175

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.  Loan is an ARM.

Buyer Comment (2019-08-22): XXXXXX has elected to waive this exception.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207902175

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Buyer Comment (2019-08-22): XXXXXX has elected to waive this exception.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207902175

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Property Value

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed an Appraised Property Value that did not match the actual Property Value for the loan.

Appraised value is $xxxxx. Final CD indicates value at $500,000

Buyer Comment (2019-08-22): XXXXXX has elected to waive this exception.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

207902176

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $17,731.45 and disclosure timing violations.

Evidence of electronic consent not provided.

Reviewer Comment (2019-08-27): AMC received E consent dated XXXXXX. Exception Cleared. Buyer Comment (2019-08-26): Econsent provided

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902176

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Evidence of delivery of LE within 3 days of  application not provided.

Reviewer Comment (2019-08-27): AMC received E consent dated XXXXXX. Exception Cleared.

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902176

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $15,126.95 exceeds tolerance of $14,617.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $15,126.95 exceeds tolerance of $14,617.00. Evidence of sufficient cure not provided.

Reviewer Comment (2019-08-27): AMC received E consent dated XXXXXX. Exception Cleared.

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902176

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Reviewer Comment (2019-08-30): Final Closing Disclosure signed XXXXXX. Final Settlement Statement dated XXXXXX shows a disbursement date of XXXXXX. Buyer Comment (2019-08-29): The loan closed on X/X, 3 business days would be 8/10 (Saturday is a business and funding day), funding on Monday 8/12. Please advise.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902176

XXXXXX

XXXXXX

Compliance

Compliance

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 Cancel occurs prior to expected date(s).

Right to Cancel signed n XXXX19. Expiration shown as XXXX19. Actual should be XXXX19

Reviewer Comment (2019-08-30): Final Closing Disclosure signed XXXXXX. Final Settlement Statement dated XXXXXX shows a disbursement date of XXXXXX. Buyer Comment (2019-08-29): The loan closed on X/X, 3 business days would be 8/10 (Saturday is a business and funding day), funding on Monday 8/12. Please advise.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902176

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Closing Costs Financed

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.

Final Closing Disclosure provided on XXXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.  Two disclosed figures are $25,785.18 and zero ($.00)

Reviewer Comment (2019-08-30): Corrected fee entry names on LE and initial CD to Electronic document delivery fee as disclosed on the interim and final CD.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902176

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.  Page 3 of CD is blank. Amount to cure is $600.45. No evidence in file that cure was provided to Borrower

Reviewer Comment (2019-08-30): Corrected fee entry names on LE and initial CD to Electronic document delivery fee as disclosed on the interim and final CD.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902176

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Electronic Document Delivery Fee.  Fee Amount of $90.50 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Electronic Document Delivery Fee increased to $90.50 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure was provided to Borrower

Reviewer Comment (2019-08-30): Corrected fee entry names on LE and initial CD to Electronic document delivery fee as disclosed on the interim and final CD. Buyer Comment (2019-08-30): The Technology was always disclosed to the Borrower, on the LE under B as "Technology Fee" $91, see D0070 and D0071.  It is actual .50 less on the final CD. Please review and advise.  Thank you.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902176

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Closing Costs Financed

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.

Closing costs financed does not match calculated

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902177

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Missing

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to consumer.

Creditor did not provide "Right to Receive a Copy" appraisal disclosure to consumer.

Buyer Comment (2019-08-22): XXXXXX has elected to waived this exception.

08/22/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

B

B

A

A

B

B

A

A

N/A

N/A

No

207902178

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Hazard Insurance policy doesn't list "Lender its successors and assigns"

Reviewer Comment (2019-08-26): Hazard Insurance policy list "Lender its successors and assigns" provided.

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902178

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Negative Fees

TRID-RESPA Integrated Disclosure - Final Closing Disclosure provided on XXXXXX disclosed a negative fee amount.

Final Closings Disclosure indicates a negative fee amount for title - misc in the amount of -$1,800.00.

Buyer Comment (2019-08-23): waive

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902178

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

Final Closing Disclosure did not disclose any Seller paid fees on page 2 and no seller CD provided.

Reviewer Comment (2019-08-27): Letter of Explanation & Corrected Closing Disclosure provided Reviewer Comment (2019-08-23): AMC received ALTA SS however, Seller's CD not provided and corrected CD disclosing the seller closing costs was not provided.

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902178

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-23): waive

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902178

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing ownership % of the xxxxx as per the articles of incorporation 100,000 shares were authorized to distribute unable to determine who owns shares.

Reviewer Comment (2019-08-23): AMC received the CPA with ownership % verified at 50% from XX-XX.

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902179

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Lender approved exception for the borrower being self employed for 12 months, program requirement is 24

37.83432% DTI on this Alt documentation loan < 43% guideline max - 5.16568% below program guideline maximum No credit late payments in the past 48 months (since 2015, 30- day revolving late) and no public records. Credit score is 754, 74 points > program requirement of 680. Borrower has been in the same line of work for the past 18 years XXXXXX LTV is 60%, 30% < program maximum of 90%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-22): Client has elected to waive this exception based on compensating factors.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902179

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $820.00 exceeds tolerance of $750.00.  Sufficient or excess cure was provided to the borrower at Closing.

08/21/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

B

B

A

A

A

A

Non QM

Non QM

Yes

207902180

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Buyer Comment (2019-08-26): XXXXXX elects to waive this exception.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902180

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $612.00 exceeds tolerance of $536.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $612.00 exceeds tolerance of $536.00.  Missing proof of valid change, insufficient or no cure was provided to the borrower

Reviewer Comment (2019-08-27): AMC received XX26 COC. Exception Cleared. Buyer Comment (2019-08-26): Please see attached VCOC

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902180

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing business % ownership as required per the guides for self employed bank statement program.

Reviewer Comment (2019-08-27): Real estate sales person license provided. Buyer Comment (2019-08-26): See attached Reviewer Comment (2019-08-26): Provided real estate sales person license fro borrower. Buyer Comment (2019-08-26): Please see attached.  Borrower is a licensed real estate sales person and works under a brokers license for himself.

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902180

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Assignment Fee.  Fee Amount of $124.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No COC for addition of fee or cure provided.

Reviewer Comment (2019-08-27): AMC reviewed exception. The fee was outsourced by chosen provider. Exception Cleared. Buyer Comment (2019-08-26): Within the 10% tolerance threshold.

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902181

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-08-23): Approval provided Buyer Comment (2019-08-22): Approval uploaded for review.

08/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

A

A

A

A

Non QM

Non QM

No

207902182

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.   Amount to cure is $1,530.20. No evidence cure provided to borrower

Reviewer Comment (2019-08-26): Tolerance exceptions are addressed. Exception Cleared.

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902182

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,100.00 exceeds tolerance of $750.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,100.00 exceeds tolerance of $750.00.  Insufficient or no cure was provided to the borrower

Reviewer Comment (2019-08-26): A cure is indicated on the final CD. Exception Cleared. Buyer Comment (2019-08-26): Please see FINAL CD section J reflecting a $350 cure was provided at closing

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902182

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Settlement / Closing / Escrow Fee.  Fee Amount of $874.40 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Title - Settlement fee increased to $874.40 without a valid change circumstance.  Tolerance exceeded. No evidence in file that cure was provided to the borrower.

Reviewer Comment (2019-08-26): AMC reviewed exception. Upon further review exception may be cleared.

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902182

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Lender's Title Insurance.  Fee Amount of $655.80 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Title - Lender's Title Insurance fee increased to $655.80 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-08-26): AMC reviewed exception. Upon further review exception may be cleared.

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902182

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation disclosure not provided:

Buyer Comment (2019-08-26): XXXXXX has elected to waive this exception

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902182

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to use combined business XXXXXX  opened XX21019 and personal bank statements XXXXXX  opened XXXX for XXXXXX  vs. program requirement that most recent 12 months business bank statement be used for qualifying income

34.25852% DTI on this Alt documentation loan < 50% guideline max - 15.74148% below program guideline maximum Only 1x30 on a credit card in XXXXXX on entire credit report for both borrowers going back to earliest account inception date of XXXXX and no public records. Co Borrower has been self employed as XXXXXX for the past 3 years

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-23): Client has elected to waive this exception based on compensating factors.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902182

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-26): XXXXXX has elected to waive this exception

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902182

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Reviewer Comment (2019-08-28): Adjusted assets with additional account to satisfy reserves. Buyer Comment (2019-08-27): Please see XXXXXX AUg 10 reflecting balance of $21673 after exluding Gift funds of $10,000, $10,500, and $4600, please see XXXXXX Jul 31 reflecting combined balance of $13,975 for 7 different accounts

08/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902182

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrower has been self-employed as XXXXXX  for 14 months vs program minimum requirement of a full two years pf self-employment (note: prior to 14 months ago the borrower was XXXXXX  but decided to choose a different path).

34.25852% DTI on this Alt documentation loan < 50% guideline max - 15.74148% below program guideline maximum Only 1x30 on a credit card in XXXXXX on entire credit report for both borrowers going back to earliest account inception date of XXXXX and no public records. Co Borrower has been self employed as XXXXXX for the past 3 years

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-23): Client has elected to waive this exception based on compensating factors.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902182

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-08-28): Adjusted assets with additional account to satisfy cash to close. Buyer Comment (2019-08-27): Please see XXXXXX Aug 10 reflecting balance of $21,673 after excluding Gift funds of $10,000, $10,500 and $4600; please see XXXXXX Jul 31 reflecting combined balances of $13,975 for 7 different accounts

08/28/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902182

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,100.00 exceeds tolerance of $750.00.  Sufficient or excess cure was provided to the borrower at Closing.

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902183

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation disclosure not provided.Unable to determine if compensation was based on a term of the transaction

Buyer Comment (2019-08-23): XXXXXX has elected to waive

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902183

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Escrow waiver not allowed per guidelines.

Final CD does not reflect that taxes and insurance are escrowed which is required per guidelines.

Credit history reflects paid as agreed with the exception of two revolving 30 day lates in XXXXXX and XXXXXX. No public records Borrower has been employed in the same line of business for the past 6 years. Co-borrower has been employed for the past 10 years as XXXXXX DTI is 45.88676%, 4.11324% < program maximum of 50% Reserves are 20.12 months , 8.12 months > program requirement of 12 months 750 representative FICO score > 680 guideline minimum - 70 points above guideline minimum 65% LTV < 85% guideline max

Originator Originator Originator Originator Originator Originator

Reviewer Comment (2019-08-29): Client has elected to waive this exception based on compensating factors. Buyer Comment (2019-08-28): Lock was locked with escrow waiver Reviewer Comment (2019-08-26): Guidelines section 14.2 Escrow Accounts:  XXXXXX requires that loans sold to XXXXXX include a provision mandating escrow accounts (impound) for the payment of real estate taxes, hazard insurance and flood insurance. Initial escrow balances must (i) include sufficient funds, so that, when added to the collection of monthly escrow deposits, XXXXXX will have funds to pay required tax and insurance disbursements, plus (ii) the maximum escrow cushion permitted (1/6 of estimated annual escrow distributions). Buyer Comment (2019-08-23): Per final CD, borrower declined escrows

08/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902183

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Paid To party cannot be determined on the Closing Disclosure. For compliance testing purposes, Paid To of Lender will be considered in lieu of UTD.

- ___

Buyer Comment (2019-08-23): XXXXXX has elected to waive

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207902183

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section C Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Closing Disclosure provided on XXXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Shop For.

Notary fee is listed as UTD.

Buyer Comment (2019-08-23): XXXXXX has elected to waive

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good Faith Redisclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207902184

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Flood Certificate not provided

Reviewer Comment (2019-08-26): Flood Cert provided

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing

FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Notice of Special Flood Hazard Disclosure.

Buyer Comment (2019-08-26): waive

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-26): waive

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Loan closed XXXXXX -  Missing XX Tax Returns The tax returns used were not current based on the closing date. the filing of the extension does not make the stale returns current, it just means the consumer is deferring their filing with the IRS. Specifically the income being used to qualify is not based on recent returns.

Buyer Comment (2019-08-26): waive

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charge is underdisclosed by $88 which appears that the Lender did not include the Title Misc Charges of $90 in APR. Please provide the final Compliance report from the final CD.

Reviewer Comment (2019-08-28): SitusAMC received required documents, exception is cured. Reviewer Comment (2019-08-27): Copy of refund check required in order to address the exception. Buyer Comment (2019-08-26): uploaded pccd/RTC/lox/refund

08/28/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD reflects only $21.95 in fees that exceeded the legal limit.

Reviewer Comment (2019-08-27): SitusAMC received required documents, exception was cured at closing.. Buyer Comment (2019-08-26): uploaded pccd/RTC/lox/refund

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-2,337.50  is less than amount of binding Lender Credit previously disclosed in the amount of $-9,000.00.

Revised LE dated XXXX19 reflected a Lender Credit in the amount of $9,000 yet the final CD shows only $2,337.50.

Reviewer Comment (2019-08-28): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-27): uploaded COC that reflects interest rate lock with .250% origination credit Reviewer Comment (2019-08-27): No changed circumstance located in loan file that explains the reduction in the lender credit.

08/28/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $146.95 exceeds tolerance of $125.00.  Insufficient or no cure was provided to the borrower.

Lender provided a credit of $21.95 to cure the amount that exceeded the legal limit.  Credit will be allocated when other tolerance exceptions cleared/cured.

Reviewer Comment (2019-08-28): SitusAMC received required documents, exception is cured at closing. Buyer Comment (2019-08-27): cure applied on final CD. Please refer to pg 2 of the CD under section J Reviewer Comment (2019-08-27): Cured in error. Reviewer Comment (2019-08-27): SitusAMC received required documents, exception was cured at closing.. Buyer Comment (2019-08-26): Cure applied on final CD

08/28/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Service Charges.  Fee Amount of $95.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Initial LE did not reflect title service charges yet the final CD shows a charge in the amount of $95.

Reviewer Comment (2019-08-28): SitusAMC received required documents, exception is cured. Buyer Comment (2019-08-27): uploaded pccd/refund check Reviewer Comment (2019-08-27): Cured in error. Reviewer Comment (2019-08-27): SitusAMC received required documents, exception was cured at closing.. Buyer Comment (2019-08-26): uploaded pccd/RTC/lox/refund

08/28/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $550.00 exceeds tolerance of $500.00.  Insufficient or no cure was provided to the borrower.

Initial LE reflected Title Endorsement fees in the amount of $500 yet the final CD shows a charge of $550.

Reviewer Comment (2019-08-27): SitusAMC received required documents, exception was cured at closing.. Buyer Comment (2019-08-26): uploaded pccd/RTC/lox/refund

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Final CD dated XXXX19 reflects disbursement date of XXXX19 vs. XXXX19.

Reviewer Comment (2019-08-27): PCCD issued XXXXXX with a disbursement date of XXXXXX.

08/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902184

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Reserves in the amount of 1.33 is less than the minimum of 4 months required per guidelines.

Reviewer Comment (2019-08-26): Agree with lender. Buyer Comment (2019-08-26): reserves were waived based on section 10.4 of guidelines

08/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902184

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 8/6/XX 12:00:00 AM was received.

Revised LE dated XXXX19 was not acknowledged as being received prior to initial CD dated XXXX19.

Buyer Comment (2019-08-26): waive

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902185

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrower have a total of 18 months self-employment vs program requirement that the borrower must have continually self-employed for 2 years.

No public records DTI is 34.78865%, 15.21135% < program maximum of 50% Borrower has employment stability for 5 years in XXXXXX Reserves are 11.53 months, 8.53 months > program requirement of 3  months Credit score is 673, 33 points > program requirement of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-23): Client has elected to waive this exception based on compensating factors.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902185

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

no cure amount provided

Buyer Comment (2019-08-26): XXXXXX has elected to waive this exception.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902185

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Municipal Lien Certificate Fee (MLC).  Fee Amount of $112.80 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No COC or cure provided.

Reviewer Comment (2019-08-27): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided Buyer Comment (2019-08-26): PCCD/LOX/Refund/Label uploaded.

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902185

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow to use 6 months business bank statements and 6 months person bank statements vs program requirement of using all business bank statement.

No public records DTI is 34.78865%, 15.21135% < program maximum of 50% Borrower has employment stability for 5 years in XXXXXX Reserves are 11.53 months, 8.53 months > program requirement of 3  months Credit score is 673, 33 points > program requirement of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-23): Client has elected to waive this exception based on compensating factors.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902185

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

-

No public records DTI is 34.78865%, 15.21135% < program maximum of 50% Borrower has employment stability for 5 years in XXXXXX Reserves are 11.53 months, 8.53 months > program requirement of 3  months Credit score is 673, 33 points > program requirement of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-23): Client has elected to waive this exception based on compensating factors.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902185

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Municipal Lien Certificate Fee (MLC).  Fee Amount of $112.80 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

Reviewer Comment (2019-08-27): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902186

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-28): XXXXXX has elected to waive this exception.

08/28/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902186

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Lender acknowledged exception to allow LTV > program

17.50205% DTI on this Alt  documentation loan < 50% guideline max - 32.49795% below program guideline maximum Borrower 1 has two credit scores (646 and 695) being a Foreign National.  No mortgage late payments in the past 19 months (since XXXXXX) and no public records. Borrowers have been XXXXXX for the past 15 years Reserves are 19.77 months , 6.77 months > program requirement of 13 months (12 months + 1 additional month for additional investment property owned)

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-27): Client has elected to waive this exception based on compensating factors.

08/27/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902186

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Combined loan to value discrepancy.

Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___.

Lender acknowledged exception to allow LTV > program

17.50205% DTI on this Alt  documentation loan < 50% guideline max - 32.49795% below program guideline maximum Borrower 1 has two credit scores (646 and 695) being a Foreign National.  No mortgage late payments in the past 19 months (since XXXXXX) and no public records. Borrowers have been XXXXXX for the past 15 years Reserves are 19.77 months , 6.77 months > program requirement of 13 months (12 months + 1 additional month for additional investment property owned)

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-27): Client has elected to waive this exception based on compensating factors.

08/27/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902186

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Lender approved exception for loan amount of $xxxxx exceeds guideline limit of $3,000,000

17.50205% DTI on this Alt  documentation loan < 50% guideline max - 32.49795% below program guideline maximum Borrower 1 has two credit scores (646 and 695) being a Foreign National.  No mortgage late payments in the past 19 months (since XXXXXX) and no public records. Borrowers have been XXXXXX for the past 15 years Reserves are 19.77 months , 6.77 months > program requirement of 13 months (12 months + 1 additional month for additional investment property owned)

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-27): Client has elected to waive this exception based on compensating factors.

08/27/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902186

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Borrower is foreign national CPA letter provided on letterhead translated into English with YTD and prior years income provided - missing CPA license.

Reviewer Comment (2019-09-05): Non-QM Loan Buyer Comment (2019-09-04): CPA license uploaded. Reviewer Comment (2019-08-29): Document provided XXXXXX is an identity card and makes no reference to the CPA license. Documents was not translated from Spanish to English. Buyer Comment (2019-08-28): CPA license uploaded

09/05/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Lender to provide updated ATR/QM status

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902186

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Borrower is foreign national CPA letter provided on letterhead translated into English with YTD and prior years income provided - missing CPA license.

Reviewer Comment (2019-09-05): CPA Letter provided meets the guideline requirements for Foreign Nationals Buyer Comment (2019-09-04): CPA license uploaded. Reviewer Comment (2019-08-29): Document provided XXXXXX is an identity card and makes no reference to the CPA license. Documents was not translated from Spanish to English. Buyer Comment (2019-08-28): CPA license uploaded

09/05/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902186

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Borrower is foreign national CPA letter provided on letterhead translated into English with YTD and prior years income provided - missing CPA license.

Reviewer Comment (2019-09-05): CPA Letter provided meets the guideline requirements for Foreign Nationals Buyer Comment (2019-09-04): CPA license uploaded. Reviewer Comment (2019-08-29): Document provided XXXXXX is an identity card and makes no reference to the CPA license. Documents was not translated from Spanish to English. Buyer Comment (2019-08-28): CPA license uploaded

09/05/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207902186

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Electronic Document Storage.  Fee Amount of $55.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

No COC or cure provided

08/27/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207902187

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $550.00.  Insufficient or no cure was provided to the borrower.

Cure of $100 was provided on the final CD not allocated until additional open tolerance exception has been cured.

Reviewer Comment (2019-09-03): SitusAMC received required documents, exception is cured. Buyer Comment (2019-08-30): Cure provided on final CD

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902187

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $423.50 exceeds tolerance of $400.00.  Insufficient or no cure was provided to the borrower.

Fee disclosed as $400 on initial LE dated XXXXXX, but disclosed as $423.50 on Final Closing Disclosure.

Reviewer Comment (2019-09-03): SitusAMC received required documents, exception is cured.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902187

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for Title - Endorsement Fee of $23.50 was not provided.

Reviewer Comment (2019-09-03): SitusAMC received required documents, exception is cured. Buyer Comment (2019-08-30): uploaded pccd

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902187

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

Line 4 of Section F, number of months is blank.

Buyer Comment (2019-08-30): waive

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902187

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-30): waive

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902187

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $650.00 exceeds tolerance of $550.00.  Sufficient or excess cure was provided to the borrower.

SitusAMC received required documents, exception is cured.

Reviewer Comment (2019-09-03): SitusAMC received required documents, exception is cured.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902187

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $423.50 exceeds tolerance of $400.00.  Sufficient or excess cure was provided to the borrower.

SitusAMC received required documents, exception is cured.

Reviewer Comment (2019-09-03): SitusAMC received required documents, exception is cured.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902188

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-27): XXXXXX has elected to waive this exception

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902189

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Lender approved exception to allow reserves to be waived with mortgage payment history of 12 months (0x30x12) vs program requirement of 24 month history (0x30x24)

One open mortgage reflects paid as agreed since XXXXXX. No public records. Borrower has been self-employed for the past 19 years as XXXXXX, in the same line of business for the past 23 years. 33.29393% DTI < 43% guideline max,9.70607% below guideline maximum 718 representative FICO score > 680 guideline minimum 62.53% LTV < 90% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-27): Client has elected to waive this exception based on compensating factors.

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

B

B

B

B

A

A

A

A

Non QM

Non QM

No

207902190

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-29): waive

08/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902190

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-08-29): Agree with lender. Buyer Comment (2019-08-29): Total Assets needed were $33,906.95 ($29,270.54 in cash to close and $4636.41 in reserves)

08/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902190

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

Additional CD provided is not final as issue date of XXXXXX is prior to the signed date XXXX19.

Reviewer Comment (2019-08-30): Letter of Explanation & Corrected Closing Disclosure provided. Reviewer Comment (2019-08-30): Corrected Closing Disclosure,  LOE to borrower still required to cure Buyer Comment (2019-08-29): Uploaded PCCD that reflects seller paid fees

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902190

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Additional CD provided is not final as issue date of XXXXXX is prior to the signed date XXXX19.

Reviewer Comment (2019-08-30): Fee disclosed in Section C on LE reconciled to Section B  and Fee paid to borrower chosen provider. - no tolerance

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902190

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $500.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Additional CD provided is not final as issue date of XXXXXX is prior to the signed date XXXX19.

Reviewer Comment (2019-08-30): Fee disclosed in Section C on LE reconciled to Section B Buyer Comment (2019-08-29): Survey disclosed in section C on initial LE as $500

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902190

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Examination Fee.  Fee Amount of $415.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Additional CD provided is not final as issue date of XXXXXX is prior to the signed date XXXX19.

Reviewer Comment (2019-08-30): Fee paid to borrower chosen provider. - no tolerance

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902191

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Lender name on appraisal was for the broker and did not match lender on note

Reviewer Comment (2019-08-29): AMC received the appraisal transfer letter.

08/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

A

B

A

Non QM

Non QM

No

207902191

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Broker name listed on appraisal, creating a compliance failure

Reviewer Comment (2019-08-29): AMC received the appraisal transfer letter dated 7/XXXX for the subject property. Buyer Comment (2019-08-29): Transfer Letter

08/29/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

A

B

A

Non QM

Non QM

No

207902191

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow a profit and loss statement prepared by a Tax Preparer (with 85% profit margin) to be used vs program requirements

Perfect credit history since inception of earliest account opened XXXXXX. VOR reflects 0x30 since inception XXXXXX, no public records 85% LTV, 5% < program maximum of 90% Borrower has been self-employed for the past 10 years as XXXXXX 18.31 months reserves > 3 months guideline minimum 736 representative FICO score > 680 guideline minimum - 56 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-28): Client has elected to waive this exception based on compensating factors.

08/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

A

B

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Reviewer Comment (2019-08-30): Appraisal report provided Buyer Comment (2019-08-29): Appraisal has been uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2019-08-30): FEMA disaster end date is XXXXXX. Appraisal report effective XXXXXX provided Buyer Comment (2019-08-29): Appraisal uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Reviewer Comment (2019-08-30): Appraisal report provided Buyer Comment (2019-08-29): Appraisal uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 5.92080% or Final Disclosure APR of 5.93000% is in excess of allowable threshold of APOR 4.30% + 1.5%, or 5.80000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-08-30): Appraisal report effective XXXXXX provided Buyer Comment (2019-08-29): Appraisal uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Reviewer Comment (2019-08-30): Appraisal report effective XXXXXX provided Buyer Comment (2019-08-29): Appraisal uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

Unable to determine compliance with timely delivery of valuation to borrower due to missing information.

Reviewer Comment (2019-08-30): Appraisal report effective XXXXXX provided Buyer Comment (2019-08-29): Appraisal has been uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal - Did Not Physically Visit)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained by physical visit to property.

Reviewer Comment (2019-08-30): Appraisal report effective XXXXXX provided Buyer Comment (2019-08-29): Appraisal uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Appraisal Flipped Property Missing Information

Last Sales Price or Last Sales Date from the Primary Valuation or Contract Sales Price or Contract Sales Date are missing. Unable to determine compliance with TIL HPML Flipped Property Requirements.

Appraisal is missing from file

Reviewer Comment (2019-08-30): Appraisal report effective XXXXXX provided Buyer Comment (2019-08-29): Appraisal uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-29): XXXXXX has elected to waive this exception.

08/29/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charges under disclosed by $250 due to the Compliance Audit / Quality Control Fee of $250

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

D

B

D

A

C

B

C

A

Non QM

Non QM

Yes

207902194

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: Closing Disclosure is incomplete

LE with issued date of XXXX19 missing page 3 of 3

Reviewer Comment (2019-08-30): Page 3 of LE provided Buyer Comment (2019-08-29): 8/6 LE page 3 uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Appraisal is missing from file

Reviewer Comment (2019-08-30): Appraisal report effective XXXXXX provided Buyer Comment (2019-08-29): Appraisal uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Needed to determine percentage of ownership

Reviewer Comment (2019-08-30): Corporation documentation provided. Reviewer Comment (2019-08-30): Divorce Decree dated XXXXXX reflects the awarding of 100% interest in the business to the Borrower. CPA letter is required as all corporate documents as dated XX and XX. Buyer Comment (2019-08-29): LLC ownership documentation uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Loan Estimate 5 Year Paid Off

TILA-RESPA Integrated Disclosure - Comparisons: Loan Estimate provided on XXXXXX did not disclose the total principal paid off in 5 years.

Missing page 5

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-29): The information in question is located on page 3 of the 8/6 LE, which has been uploaded for review.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Can Only Cure by Final LE, not on CD Once the initial CD is issued this cannot be cured

D

B

D

A

C

B

C

A

Non QM

Non QM

Yes

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Loan Estimate 5 Year Payments

TILA-RESPA Integrated Disclosure - Comparisons: Loan Estimate provided on XXXXXX did not disclose the total principal paid off in 5 years.

Missing page 5

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Can Only Cure by Final LE, not on CD Once the initial CD is issued this cannot be cured

D

B

D

A

C

B

C

A

Non QM

Non QM

Yes

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Unable to test disclosure of Home Loan Toolkit due to missing information.

Missing date issued

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-29): Initial disclosure tracking uploaded, denotes home loan toolkit provided.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902194

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

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

Missing date issued

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-08-29): Initial disclosure tracking uploaded, denotes home loan toolkit provided.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

D

A

C

B

C

A

Non QM

Non QM

No

207902195

XXXXXX

XXXXXX

Credit

Property - Appraisal

Property Eligibility - Subject and Improvements

Guideline Issue:  Property type not allowed per credit guidelines

Subject Property is on xx.xx acres vs program maximum of 15 acres.  Approved Lender Exception in file.

No public records. Borrower has been self-employed for the past 10 years as XXXXX and in the same line of work for 30 years. DTI is  29.86%, 13.14% < program maximum of 43% Credit score is 688, 8 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-30): Client has elected to waive this exception based on compensating factors.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902195

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Guideline Requirement: Available for Closing discrepancy.

Calculated Available for Closing of ___ is less than Guideline Available for Closing of ___.

Allow earnest money deposit of $xxx directly from business account wired directly to escrow vs program requirement that funds for down payment and closing costs must be transferred to borrowers personal account.  Approved Lender Exception in file.

No public records. Borrower has been self-employed for the past 10 years as XXXXX and in the same line of work for 30 years. DTI is  29.86%, 13.14% < program maximum of 43% Credit score is 688, 8 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-30): Client has elected to waive this exception based on compensating factors.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902195

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation disclosure not provided. Unable to determine if compensation was based on a term of the transaction

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902195

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

Final Closing Disclosure did not provide the number of months for Property Tax under prepaids

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

207902195

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

YSP present on final CD.  Missing evidence Anti Steering Disclosure was provided to the borrower.

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

207902196

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902196

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,000.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207902196

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section C Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Closing Disclosure provided on XXXXXX reflects a fee Paid To lender or broker for fee within Services Borrower Did Shop For.

The providers for Title search, attorney, and recording fees was left blank.

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good Faith Redisclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207902196

XXXXXX

XXXXXX

Compliance

Compliance

Miscellaneous Compliance

Paid To party cannot be determined on the Closing Disclosure. For compliance testing purposes, Paid To of Lender will be considered in lieu of UTD.

- ___

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-30): Supplemental title report provided. Buyer Comment (2019-08-30): Supplemental title report uploaded.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

one appraisal reflects HOA dues annually at $1,000 the other at $1,100 and CD reflects collection at $1,100.04.

Reviewer Comment (2019-09-05): Used higher value of $1,100 from appraisal Buyer Comment (2019-09-04): PCCD/LOX/Label uploaded.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

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

Missing business tax transcripts

Reviewer Comment (2019-09-04): Required income docs were provided. Reviewer Comment (2019-09-04): 1003 shows the business is located in XXXXXX. XXXXXXApplication to Register a Foreign LLC filed XXXXXX shows the LLC was formed XXXXXX in XXXXXX and the current address is XXXXXX. A certificate of Good Standing dated XXXXXX from XXXXXX was provided. Buyer Comment (2019-09-03): Business license has been filed in XXXXXX instead of XXXXXX. Please see active license uploaded. Reviewer Comment (2019-09-03): Agree business tax transcripts are not required. However, there is no current third-party verification that the business is still active. The business license provided has expired. Buyer Comment (2019-08-30): Per guide, page 86, business tax transcripts not required. Uploaded personal transcripts which include S Corp Buyer Comment (2019-08-30): Tax transcripts uploaded

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

Missing business tax transcripts

Reviewer Comment (2019-09-04): Required income docs were provided. Reviewer Comment (2019-09-04): 1003 shows the business is located in XXXXXX. XXXXXX Application to Register a Foreign LLC filed XXXXXX shows the LLC was formed XXXXXX in XXXXXX and the current address is XXXXXX. A certificate of Good Standing dated XXXXXX from XXXXXX was provided. Buyer Comment (2019-09-03): Business license has been filed in XXXXXX instead of XXXXXX. Please see active license uploaded. Reviewer Comment (2019-09-03): Agree business tax transcripts are not required. However, there is no current third-party verification that the business is still active. The business license provided has expired. Buyer Comment (2019-08-30): Per guide, page 86, business tax transcripts not required. Uploaded personal transcripts which include S Corp

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

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

Missing business tax transcripts

Reviewer Comment (2019-09-04): Required income docs were provided.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.$850.00

Reviewer Comment (2019-09-03): All tolerance exceptions have been addressed

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-3,194.00.

Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00 is less than amount of binding Lender Credit previously disclosed in the amount of $-3,194.00.

Reviewer Comment (2019-09-03): Valid COC provided. Buyer Comment (2019-08-30): 8/8 Change of circumstance uploaded

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $850.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Second Appraisal Fee. Fee Amount of $850.00 exceeds tolerance of $0.00. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-09-03): Cured at closing Buyer Comment (2019-08-30): Executed CD with lender credit of $850 uploaded.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

rojected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 of $XXXXX that does not match the actual total payment for the loan of $XXXXX.

Reviewer Comment (2019-09-05): Letter of Explanation, Proof of Delivery, Corrected CD provided Buyer Comment (2019-09-04): PCCD/LOX/Label uploaded.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids of $22,729.26 that does not match amount per month calculation of$25,892.28

Buyer Comment (2019-09-04): XXXXXX has elected to waive this exception.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Missing documentation confirming the monthly hazard insurance payment for the REO located at XXXXXX

Reviewer Comment (2019-09-03): Evidence of insurance provided is an Application/Binder-Receipt. Document has an effective date of XXXXXX and is valid for 90 days. Buyer Comment (2019-08-30): HOI for XXXXXX uploaded.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902197

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $850.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Cured at closing

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207902197

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow subject to close in borrowers LLC (100% owner of XXXXXX ) vs program requirement to close as a natural person.

Borrower has been self employed fr the past 3 years as XXXXXX Mortgage history with 1 active mortgage paid as a freed since an isolated 30 day late XXXXXX with no  other late payments since inception XXXXXX. No public records 13.09158% DTI on this full documentation loan < 50% guideline max - 36.90842% below program guideline maximum 113.32 months reserves > 14 months guideline minimum Credit score is 687, 7 points > program requirement of 680 LTV is 70%, 5% < program maximum of 75%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-05): Client has elected to waive this exception based on compensating factors.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902197

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow funds for closing  to come from business account (due to transaction closing in LLC name) vs program requirement that funds for closing be transferred to borrowers personal bank account.

Borrower has been self employed fr the past 3 years as XXXXXX Mortgage history with 1 active mortgage paid as a freed since an isolated 30 day late XXXXXX with no  other late payments since inception XXXXXX. No public records 13.09158% DTI on this full documentation loan < 50% guideline max - 36.90842% below program guideline maximum 113.32 months reserves > 14 months guideline minimum Credit score is 687, 7 points > program requirement of 680 LTV is 70%, 5% < program maximum of 75%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-05): Client has elected to waive this exception based on compensating factors.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207902198

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Borrower does not have the minimum active tradelines per guidelines.

Borrower has 2 trade lines reporting 12 + months vs. program requirement of a minimum of 3 trade lines reporting 12+ months. In addition, only 1 active trade reporting in the past 12 months that has been established for 12+ months vs. program requirement of 2 active trade lines.

Reviewer Comment (2019-09-04): Agree with lender. VOM - XXXXXX rated 64 months active 6/19, XXXXXX rated 28 months active 1/XX, XXXXXXXXXXXX active for 5 mon and XXXXXX XXXXXX closed rated 44 months. Buyer Comment (2019-09-04): Borrower meets trade-line requirement with the following: VOM - XXXXXX rated 64 months active 6/19, XXXXXX rated 28 months active 1/XX and XXXXXX XXXXXX closed rated 44 months.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902198

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Policy amount on title is $300,000 vs. required amount of XXXXXXto cover loan amount.

Reviewer Comment (2019-09-05): Updated title commitment provided.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902198

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-09-04): XXXXXX has elected to waive this exception

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902198

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-04): XXXXXX has elected to waive this exception.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902198

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

Colorado Home Loan (Tangible Net Benefit Disclosure Not Signed)

XXXXXX Home Loan (HB1322):  Tangible Net Benefit Disclosure (or similar document) not signed by borrower(s).

Buyer Comment (2019-09-04): XXXXXX has elected to waive this exception.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902198

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

Final CD reflects a monthly HOI premium of $190.09 or $2,281 annually vs. actual annual premium on policy of $2,377.

Reviewer Comment (2019-09-05): Letter of Explanation, Proof of Delivery, Corrected CD provided. Rescission not required to be re-opened as IEAD matched Final CD. Buyer Comment (2019-09-04): Uploaded For Review: PCCD Docs

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

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

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

207902198

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 8/XXXX 12:00:00 AM was received.

Revised LE dated XXXX19 was not acknowledged as being received prior to initial CD dated XXXX19.

Buyer Comment (2019-09-04): XXXXXX has elected to waive this exception

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902198

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Title Error: Title vesting does not concur with deed

Commitment and Warranty Deed indicate subject vested in LLC

Reviewer Comment (2019-09-06): Quit claim with legal description provided. Buyer Comment (2019-09-05): Deed including Legal Description Reviewer Comment (2019-09-05): Commitment updated to reflect policy amount same as loan amount. The Title commitment shows title is vested in the LLC. Schedule B Part I item 4 is requiring a Warranty Deed from the LLC to the Borrower. Quit Claim Deed provided for transfer from LLC to the Borrower is missing the legal description. Reviewer Comment (2019-09-05): Quit Claim Deed provided. Buyer Comment (2019-09-04): Uploaded For Review: Quit Claim Deed Buyer Comment (2019-09-04): Uploaded For Review: Correct Title Commitment

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902198

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

Colorado Consumer Credit Code (First Lien Refinance Notice Not Provided)

XXXXXX Consumer Credit Code: Borrower not provided First Lien Refinance Notice.

Reviewer Comment (2019-09-04): Disclosure provided. Buyer Comment (2019-09-04): Uploaded For Your Review: Disclosure

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

C

B

A

A

Non QM

Non QM

No

207902199

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-03): XXXXXX has elected to waive this exception.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902199

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Rate Spread Threshold Test Compliant

XXXXXX Rate Spread Home Loan: APR on subject loan of 6.39200% or Final Disclosure APR of 6.40700% is in excess of allowable threshold of APOR 4.30% + 1.5%, or 5.80000%.  Compliant Rate Spread Home Loan.

Buyer Comment (2019-09-03): XXXXXX has elected to waive this exception.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

207902200

XXXXXX

XXXXXX

Credit

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal not provided

Reviewer Comment (2019-09-05): Appraisal provided. Buyer Comment (2019-09-04): Appraisal uploaded for review.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

A

D

A

A

A

C

A

Non QM

Non QM

No

207902200

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: Property is located in a FEMA Disaster area and has not been inspected.

Reviewer Comment (2019-09-05): Appraisal effective date of XXXXXX. Disaster end date of XXXXXX. Buyer Comment (2019-09-04): Appraisal uploaded for review.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

A

D

A

A

A

C

A

Non QM

Non QM

No

207902200

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

Copy of full appraisal is missing

Reviewer Comment (2019-09-05): Appraisal provided. Buyer Comment (2019-09-04): Appraisal uploaded for review.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

A

D

A

A

A

C

A

Non QM

Non QM

No

207902200

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-09-06): Appraisal Receipt Confirmation provided. Buyer Comment (2019-09-05): Appraisal Receipt Confirmation docs uploaded for review.

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

A

D

A

A

A

C

A

Non QM

Non QM

No

207902201

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

12 months personal bank statements used by Lender to calculate income from account 1622 missing from file

Reviewer Comment (2019-09-04): bank statements for account XXXXXX provided. Buyer Comment (2019-09-04): Bank statements from acct XXXXXX uploaded.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902201

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for homeowner's insurance under Prepaids.

Invalid exception. Annual premium is $4,596 / 12 = $383.00 per month

Buyer Comment (2019-09-03): XXXXXX has elected to waive this exception.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207902201

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Lender acknowledged exception in file for loan amount

No public records Both Borrowers have been self-employed for the past 2 years and have been XXXXXX for 15 years. Borrower has 2 open mortgages reporting one 30 day late in XXXXXX Credit score is 718, 18 points > program requirements of 700

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-03): Client elects to waive with compensating factors

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207902202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-04): XXXXXX has elected to waive this exception.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207902202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Reviewer Comment (2019-09-05): Valid COC provided.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-3,212.16  is less than amount of binding Lender Credit previously disclosed in the amount of $-7,840.00.

Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-3,212.16  is less than amount of binding Lender Credit previously disclosed in the amount of $-7,840.00. Lenders credit reduced on XXXXXX loan estimate, file does not contain proof of valid change.

Reviewer Comment (2019-09-05): Valid COC provided. Buyer Comment (2019-09-04): COC uploaded for review.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207902203

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,175.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

A

A

A

A

A

A

A

A

Non QM

Non QM

Yes

207911186

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final Closing Disclosure incorrectly said the the loan is not assumable.

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207911186

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The closing date on the final CD is XXXX19, and the loan closed on XXXX19.

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

207911187

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 1,680.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Tax and insurance liabilities not properly reflected on final CD.

Reviewer Comment (2019-09-11): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-09-10): pccd, delivery, and property costs attached.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207911188

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing the borrower's full Fraud Report.

Reviewer Comment (2019-09-13): Received

09/13/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

A

C

A

A

A

A

A

N/A

N/A

No

207911188

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Flood Certificate not provided

File is missing the Flood Certificate for the subject property.

Reviewer Comment (2019-09-13): Received

09/13/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

A

C

A

A

A

A

A

N/A

N/A

No

207911191

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Documentation was not provided at the time of audit review.

Reviewer Comment (2019-09-13): Received

09/13/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

A

C

A

A

A

A

A

N/A

N/A

No

207911192

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Prepayment Penalty

XXXXXX Prepayment Penalty (XXXXXX Interest Act): Prepayment penalty not permissible; however Note or Prepay Addendum provides specific language that prepay will not exceed maximum permitted by applicable law.

The Prepayment Penalty Addendum states that if the rate of interest exceeds 8%. a full Prepayment can be made without a Prepayment Penalty.

Reviewer Comment (2019-09-09): EV2 waived at client request

09/09/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

N/A

N/A

No

207911194

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-09-13): Received Buyer Comment (2019-09-06): fraudguard

09/13/2019

1

A

XXXXXX

XXXXXX

Investment

Purchase

C

A

C

A

A

A

A

A

N/A

N/A

No

207911196

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-08-30): Waive per client request.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207911196

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

Final Closing Disclosure disclosed an Estimated Total Monthly Payment for Payment Stream 1 of $XXXX; calculated Estimated Total Monthly Payment is $XXXX. Difference is due to Hazard Insurance Policy reflects an annual premium of $XXXX or $XXX per month however, Final Closing Disclosure disclosed the monthly premium as $XXX. Letter of Explanation to the borrowers, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable are required to cure this exception.

Reviewer Comment (2019-09-09): Letter of Explanation, Proof of Delivery, Corrected CD provided. Rescission  not required to be re-opened as IEAD matched the Final CD Buyer Comment (2019-09-06): Please see pccd and delivery attached

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207911202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

Initial escrow account statement disclosed initial deposit of $2,143.34 and Consumer's Final CD disclosed $2,143.90.

Reviewer Comment (2019-08-22): Waive per client request.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207911202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD disclosed loan does not allow for Assumption, however, Note contains Assumption language.

Reviewer Comment (2019-08-22): Waive per client request.

08/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207911202

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

File is missing the lender's Loan Approval.

Reviewer Comment (2019-09-04): Received

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207911202

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Documentation

Missing Document: Appraisal was made "subject to" and Form 1004D/442 was not provided.

-

Appraisal was done subject to the following repairs or alterations: Completion of the pool per plans and specs. However, the file is missing a completion cert to verify the pool was completed as required.

Reviewer Comment (2019-09-12): 442 w/photos provided Buyer Comment (2019-09-09): 1004d

09/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207911202

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Verified reserves after closing of 2.85 months are insufficient to meet the guideline reserves requirement of 6 months.

Borrowers made a down payment of14.43% from their own funds on this purchase transaction. Borrower on this Full documentation loan has a disposable income of $6,680.29 773 representative FICO score >  680 guideline minimum

Originator Originator Originator

Reviewer Comment (2019-09-12): Lender's exception approval for 2.85 months reserves

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

207911202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan.

Final Closing Disclosure disclosed a monthly insurance premium of $67.00 on page 2, however, the Hazard Insurance Policy verifies the annual premium is $805.00 or $67.08 per month. Post-closing CD dated XXXXXX disclosed the correct monthly insurance premium of $67.08 however, file is missing Letter of Explanation, which is required to cure this exception.

Reviewer Comment (2019-08-26): Final revised CD issued on 5/XX19 and electronically signed on 5/XX19 corrected monthly HOI premium.  Letter of explanation is not required since it was signed, POD was email for the electronic documents.  No refund required, non-rescindable transaction.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207911202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan.

Final Closing Disclosure disclosed a monthly insurance premium of $67.00 on page 2, however, the Hazard Insurance Policy verifies the annual premium is $805.00 or $67.08 per month. Post-closing CD dated XXXXXX disclosed the correct monthly insurance premium of $67.08 however, file is missing Letter of Explanation, which is required to cure this exception.

Reviewer Comment (2019-08-26): Final revised CD issued on 5/XX19 and electronically signed on 5/XX19 corrected monthly HOI premium.  Letter of explanation is not required since it was signed, POD was email for the electronic documents.  No refund required, non-rescindable transaction.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207911202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan.

Final Closing Disclosure disclosed a monthly insurance premium of $67.00 on page 2, however, the Hazard Insurance Policy verifies the annual premium is $805.00 or $67.08 per month. Post-closing CD dated XXXXXX disclosed the correct monthly insurance premium of $67.08 however, file is missing Letter of Explanation, which is required to cure this exception.

Reviewer Comment (2019-08-26): Final revised CD issued on 5/XX19 and electronically signed on 5/XX19 corrected monthly HOI premium.  Letter of explanation is not required since it was signed, POD was email for the electronic documents.  No refund required, non-rescindable transaction.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207911202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan.

Final Closing Disclosure disclosed a monthly insurance premium of $67.00 on page 2, however, the Hazard Insurance Policy verifies the annual premium is $805.00 or $67.08 per month. Post-closing CD dated XXXXXX disclosed the correct monthly insurance premium of $67.08 however, file is missing Letter of Explanation, which is required to cure this exception.

Reviewer Comment (2019-08-26): Final revised CD issued on 5/XX19 and electronically signed on 5/XX19 corrected monthly HOI premium.  Letter of explanation is not required since it was signed, POD was email for the electronic documents.  No refund required, non-rescindable transaction.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207911202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

Final Closing Disclosure disclosed a monthly insurance premium of $67.00 on page 2, however, the Hazard Insurance Policy verifies the annual premium is $805.00 or $67.08 per month. Post-closing CD dated XXXXXX disclosed the correct monthly insurance premium of $67.08 however, file is missing Letter of Explanation, which is required to cure this exception.

Reviewer Comment (2019-08-26): Final revised CD issued on 5/XX19 and electronically signed on 5/XX19 corrected monthly HOI premium.  Letter of explanation is not required since it was signed, POD was email for the electronic documents.  No refund required, non-rescindable transaction.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207911202

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1 -  October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed a monthly insurance premium of $67.00 on page 2, however, the Hazard Insurance Policy verifies the annual premium is $805.00 or $67.08 per month. Post-closing CD dated XXXXXX disclosed the correct monthly insurance premium of $67.08 however, file is missing Letter of Explanation, which is required to cure this exception.

Reviewer Comment (2019-08-26): Final revised CD issued on 5/XX19 and electronically signed on 5/XX19 corrected monthly HOI premium.  Letter of explanation is not required since it was signed, POD was email for the electronic documents.  No refund required, non-rescindable transaction.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

207911203

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing the borrower's full Fraud Report.

Reviewer Comment (2019-09-04): received

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207911203

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows assumption, but the final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-08-23): Waive per client request.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207911203

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The date disclosed as closing on Note, Mortgage and final Closing Disclosure is XXXXXX, but the documents were signed XXXXXX.

Reviewer Comment (2019-08-23): Waive per client request.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207911203

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Non-Escrowed Property Costs over Year 1 of $6,120.00. Non-Escrowed Property Costs (HOA Dues) are $480.00 per month, which equates to calculated Escrowed Property Costs over Year 1 of $5,760.00.

Reviewer Comment (2019-09-10): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-09-06): per initial fees provided by broker and disclosed on 1003 hoa fee is $510 per month.  Lender used the higher HOA fee in lieu of amount listed on appraisal to ensure fee is not underdisclosed to borrower. please waive condition

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207911203

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Subject loan closed with an LT V of 90% however, the maximum LTV is 85% for the subject loan amount of $xxxxx. File is missing a client approved exception with verified compensating factors to allow the higher LTV.

21.96% DTI on this Full documentation loan < 50.00% guideline maximum Borrower on this Full documentation loan has a disposable income of $128,053.65 770 representative FICO score > 680 guideline minimum

Originator Originator Originator

Reviewer Comment (2019-09-12): Lender exception provided allowing 90% LTV

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207911207

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD verbiage does not match the subject Note verbiage for loan assumption.

Reviewer Comment (2019-08-28): Waive per client request.

08/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207911207

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

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

TRID non-compliant. Seller's Final Closing Disclosure did not disclose any fees and, and no seller paid fees were disclosed on the Buyer's Final Closing Disclosure. Points and Fees testing has been limited to the borrower paid fees.

Reviewer Comment (2019-09-10): New home construction.  Typical no seller paid fees. Confirmed from Final SS that the seller did not pay any fees. Buyer Comment (2019-09-09): please see final ss.  There were not any seller paid fees other than the seller credit reflected on page 3 of the CD with docs.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207911207

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Reserves after closing of 5.61 months are insufficient to cover the total reserves required of 6 months. File is missing a client approved exception with verified compensating factors to allow less than the required 6 months of reserves.

Borrower has residual income of $20,247.01 22.35% DTI on this Bank Statement documentation loan < 50.00% guideline max - 27.65% below program guideline maximum

Originator Originator

Reviewer Comment (2019-09-04): Lender approved exception to allow 5.61 months of reserves vs the guideline required 6 months.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207911208

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects that assumption is not allowed.

Reviewer Comment (2019-08-26): Waive per client request.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207911208

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 27,098.76 on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Estimated Property Costs over Year 1 of $27,098.76. Estimated Property Costs are $2,311.65 per month, which equates to calculated Escrowed Property Costs over Year 1 of $27,739.80. Letter of Explanation to the borrower and Corrected Closing Disclosure are required to cure this exception.

Reviewer Comment (2019-09-11): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-09-10): pccd and delivery

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

207911208

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Subject loan closed with an LTV of 90% which exceeds the guideline maximum of 85% for a loan amount over $1.5 million.

Borrower has been self-employed for 10.02 years 43.67% DTI on this Bank Statement documentation loan < 50.00% guideline max - 6.33% below program guideline maximum Housing payment history clean for 30 months

Originator Originator Originator

Reviewer Comment (2019-08-26): Client approved exception to allow an LTV above the guideline maximum of 85.00%.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207911208

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Verified reserves after closing are insufficient to cover the required 12 months of reserves for a loan amount above $1.5 million.

Borrower has been self-employed for 10.02 years 43.67% DTI on this Bank Statement documentation loan < 50.00% guideline max - 6.33% below program guideline maximum Housing payment history clean for 30 months

Originator Originator Originator

Reviewer Comment (2019-08-26): Client approved exception to allow only 3.13 months reserves when 12 months are required.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

207911209

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Subject loan LTV of 85.00% exceeds the Full Doc cash-out guideline maximum of 75.00% for a loan amount above $1.5 million and a minimum FICO score of 680. File is missing a client approved exception with verified compensating factors to allow the LTV of 85.00%.

0 x 30 Housing History DTI: 45.76818% Borrower on this Full documentation loan has a disposable income of $33,569.00

Originator Originator Originator

Reviewer Comment (2019-09-12): Lender exception approval provided allowing 85% LTV for cash out transaction

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207911209

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Incorrectly disclosed.  ARM Note contains assumable verbiage.  Images do not contain a Non-Assumable Rider.

Reviewer Comment (2019-08-27): Waive per client request.

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207911209

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Borrower has been employed as a XXXXXX for 7 months and income was verified with a XX YTD P&L Statement through XXXXXX and a XX P&L Statement.

Reviewer Comment (2019-08-27): Waive per client request.

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207911249

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Loan amount XXXXXX.  Estimated cost new $658,200.  Hazard coverage $366,000.  Coverage shortfall $292,200.  Replacement cost estimator is not evidenced in loan file.

Reviewer Comment (2019-07-18): Received Buyer Comment (2019-07-17): eoi replacement cost estimator

07/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

207911249

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

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

CD issued on XXXX18 does not reflect an amount by which total closing costs exceeded the legal limit.  Calculated amount is $XXX.

Reviewer Comment (2019-07-09): Waiving at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207911249

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/XXXXXX)

Seller Disclosure not evidenced in loan file.

Reviewer Comment (2019-04-26): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207911249

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $575.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower. (7506)

Fee is not reflected on LE.  No valid changed circumstance provided.  No cure provided.  Please note, LE reflects Appraisal Review Fee, but not an Appraisal Fee.

Buyer Comment (2019-07-19): unable to clear.  past 60 days Reviewer Comment (2019-07-18): No supporting documentation provided.  Appraisal invoice is dated XXXX18 with a fee of $475 for the appraisal and $100 rush fee.  The fee was not disclosed on initial LE dated XX1/18.  To cure provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD. Buyer Comment (2019-07-17): unable to cure

3

C

XXXXXX

XXXXXX

Primary

Purchase

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

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207911249

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Note contains assumption verbiage.  CD issued on XXXX18 reflects not assumable.

Reviewer Comment (2019-04-26): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

207944361

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final Closing Disclosure incorrectly says that the loan isn't assumable,

Reviewer Comment (2019-09-03): Waive per client request.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207944361

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 13,695.60 on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Estimated Property Costs over Year 1 of $13,695.60. Estimated Property Costs are $1,134.05 per month, which equates to calculated Escrowed Property Costs over Year 1 of $13,608.60. Difference of $87.00 is due to Hazard Insurance Policy reflects an annual premium of $2,118.00 or $176.50 per month however, the lender qualified with a monthly insurance premium of $183.75 which equates to an annual premium of $2,205.00. Letter of Explanation to the borrowers and Corrected Closing Disclosure are required to cure this exception.

Reviewer Comment (2019-09-19): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-09-18): Please see PCCD and Delivery

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

207944361

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Total cash-out discrepancy.

HUD-1 total cash-out of ___ is greater than Guideline total cash-out of ___.

Borrowers received $584,467.25 total cash out at closing, which exceeds the Full Doc guideline maximum of $500,000.00. File is missing the lender's approved exception with verified compensating factors to allow the excessive cash out.

26.51 months reserves > 6 months guideline minimum Borrower on this Bank Statement documentation loan has a disposable income of $14,525.52 41.28121% DTI on this Bank Statement documentation loan < 50.00% guideline maximum

Originator Originator Originator

Reviewer Comment (2019-09-12): Lender approved for $584,467.25 total cash out at closing

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

207944362

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 4,872.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Estimated Property Costs over Year 1 of $4,872.00. Estimated Property Costs are $1,764.43 per month, which equates to calculated Escrowed Property Costs over Year 1 of $21,173.16. Letter of Explanation to the borrowers and Corrected Closing Disclosure are required to cure this exception.

Reviewer Comment (2019-09-19): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-09-18): PCCD and Delivery

09/19/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207944362

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

XX extension in file.

Reviewer Comment (2019-08-28): Waive per client request.

08/28/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207944362

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

XX extension in file.

Reviewer Comment (2019-08-28): Waive per client request.

08/28/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207944362

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Closing date on CD is XXXX19. Consummation date shown on security instrument is XXXX19.

Reviewer Comment (2019-08-28): Waive per client request.

08/28/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207944362

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller CD missing from loan file.

Reviewer Comment (2019-08-28): Waive per client request.

08/28/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207944362

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

The evidence indicates the appraisal was provided on XXXX19, and the appraiser signed the appraisal on XXXX19.

Reviewer Comment (2019-08-28): Waive per client request.

08/28/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

207944364

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrower was qualified with a DTI of 24.15% and monthly business bank statement income of $59,137.95 calculated from the P&L statement average. However, the Initial 1003 disclosed a monthly bank statement income of $26,135.64. XXXXXX business Bank Statement guidelines require the lower of the income on the Initial 1003 or the P&L statement average. Using the lower 1003 income results in a DTI of 51.42%, which exceeds XXXXXX guideline maximum of 50.00%.

Housing payment history clean for 91 months Borrower has residual income of $12,697.09

Originator Originator

Reviewer Comment (2019-09-20): Lender approved exception to allow a DTI of 51.42%, which exceeds the guideline max of 50.00%.

09/20/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

207944365

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-09-13): Received

09/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207944365

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Guidelines only have loan amount up to $3,000,000.

Borrower has residual income of $65,965.35 34.03% DTI on this Bank Statement documentation loan < 50.00% guideline max - 15.97% below program guideline maximum

Originator Originator

Reviewer Comment (2019-09-19): Lender approved exception to allow a a loan amount of xxxx which exceeds the guideline max of $3,000,000.00.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207944365

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Reviewer Comment (2019-09-05): EV2 waived at client request

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

207944365

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final CD disclosed a closing date of XXXX19.  Consummation date is XXXX19.

Reviewer Comment (2019-09-05): EV2 waived at client request

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

207944367

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Fannie Mae 2014 - 3% Points and Fees

Fannie Mae 2014 3% Points and Fees Test.  Points and Fees on subject loan of XX% is in excess of the investor allowable maximum of  3.00000% of the Federal Total Loan Amount. Points and Fees total $XXXXX on a Federal Total Loan Amount of $XXXX vs. an investor allowable total of $XXXX (an overage of $XXX or .31553%).

Points and Fees for subject loan of 3.31553% exceed the 3.00% allowable maximum of the Federal total loan amount of $xxxx, and points and fees totaling $xxxx exceed the allowable maximum of $xxxx, which is an overage of $xxxx or .31553%.

Buyer Comment (2019-05-28): no qm

05/28/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207944367

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Right to Cancel executed by the borrowers on XXXXXX disclosed a rescission expiration date of XXXXXX. Final Closing Disclosure disclosed a disbursement date of XXXXXX, only providing borrowers with a 2 day rescission period.

Reviewer Comment (2019-05-30): Rec'd final CD. Reviewer Comment (2019-05-21): Rec'd settlement statement.  Need final PC CD reflecting correct disbursement date, and LOE to the borrower. Buyer Comment (2019-05-20): LOAN DISBURSED ON X/XX

05/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207944367

XXXXXX

XXXXXX

Compliance

Compliance

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 Cancel occurs prior to expected date(s).

Right to Cancel executed by the borrowers on XXXXXX disclosed a rescission expiration date of XXXXXX. Final Closing Disclosure disclosed a disbursement date of XXXXXX, only providing borrowers with a 2 day rescission period.

Reviewer Comment (2019-09-19): Cure documentation received. Reviewer Comment (2019-09-19): This exception has been escalated to our compliance department for review of the documentation provided. Buyer Comment (2019-09-04): Please see right to cancel delivery and borrower response attached.  We also previously provided the ROR form that was sent with this email to the borrower. Reviewer Comment (2019-08-16): Execution of RTC - 2/XX19 Consummation of loan - 2/XX19 Receipt of material disclosures - 2/XX19 Therefore, the rescission expiration is midnight of 2/XX19 with the first day eligible for disbursement being on 2/XX19. Note that Monday, 2/18 is Presidents Day and is therefore not counted in the rescission period.  Final Borrower Statement reflects a Disbursement Date of 2/XX19 which, while it provides adequate timing as it was not disbursed prior to the expiration, doesn't change fact the Rescission contained an incorrect expiration date of 2/XX19.  AMC has raised the issue of incorrect rescission expiration dates a few times with our counsel and they have consistently held that a date provided that is earlier than the actual expiration date would render the rescission notice defective because it gives the impression the consumer only has until X in which to rescind, when they actually had until Y.  While there may consideration for downgrading or clearing an exception where the expiration date provided is longer than the actual expiration date required, counsel has held firm when disclosing a shorter period - even with the language that says "…or midnight of the third business day following the latest of the three events listed above" as they don't believe the onus should be on the consumer to figure out what that date should be. Reviewer Comment (2019-07-08): This exception has once again been reviewed by our compliance department with this response: "Sending the original rescission back out to the borrowers to initial a revised expiration date does not change the fact the borrower was originally not provided a sufficient number of days through which to rescind.  The only remedy to fully extinguish any possibility of rescission is to provide new rescission notices that contain new expiration dates and give the borrowers another three days to rescind.  At the expiration of the new rescission, we can cure to EV2-B. Per my previous response, it is important we know when the borrowers received the new rescission in order to support the requisite three business day timeframe was provided to them. Cure requires LOE, new rescission notices and proof of delivery." Exception will remain until the documentation as required by our compliance department is provided. Reviewer Comment (2019-06-13): This exception has been reviewed by our compliance department with this response: The Rescission Expiration on the original rescission notice was 2/XX19 which did not account for Washington's Birthday (Presidents Day) and therefore should have given until 2/XX19 before funding. Lender attempted to re-open rescission on June 5th by emailing the same Rescission Notice back to borrower(s) and advising through the email that the new Rescission Expiration Date was XXX, XX.  The date on the Rescission Notice itself remained unchanged.  AMC sees two concerns with this approach: 1)  Despite the email containing a revised Expiration Date, the RTC provided continued to disclose the old date.  We have discussed the disclosure of an inaccurate rescission expiration date on the RTC with outside counsel in the past who has determined such a disclosure would render the Notice as defective given the requirement under 1026.23(b)(1) is to "clearly and conspicuously disclose" the date the rescission period expires.  There is obvious potential risk for an assignee purchasing a loan to rely solely on the argument that the borrower should have known what "midnight of the third business day following the latest of the three events listed above" actually represents. 2)  In order to re-open rescission for the borrower, the clock would start at the time the borrower receives the Rescission Notice.  Sending the RTC electrically on June 5th does not automatically start the rescission clock unless we have proof the borrower also received the transmission on that same day (i.e., opened the email).  Without this proof, we would use a Mailbox rule of three days and start clock from there.  By example, if Rescission emailed on XXX, assume delivery under Mailbox rule by XXX, Rescission expiration is midnight of XXX.  We would accept a confirmation from borrower that they did receive the email on XXX as a means of using that earlier date to start rescission clock. However, in the case here, #1 is still an issue as the Expiration Date printed on the Rescission was still inaccurate. To cure issue and properly extinguish any possibility of rescission:  (1) send revised Rescission with updated Rescission Expiration Date based on when borrower is expected to receive disclosure (i.e., rescission expiration should be 3-days from when they receive disclosure); and (2) if Rescission Expiration uses a date earlier than the 3-day Mailbox rule for borrower receipt, provide evidence of when borrower received Rescission to support the full 3-day waiting period was provided. Buyer Comment (2019-06-11): the right to cancel form doesn't change the date - see option 3 which shows the date is reopened at the date they receive the notice which was in the email.   See attached Reviewer Comment (2019-06-10): Rec'd email to borrower regarding the re-opening of rescission.  The RTC forms provided still reflect February dates. Reviewer Comment (2019-06-07): The RTC period includes a federal holiday.  Need rescission re-opened or affidavit that lender was open for business on the holiday (to be reviewed by compliance). Buyer Comment (2019-06-07): loan signed X/XX and disbursed X/XX see attached Reviewer Comment (2019-05-30): The RTC reflects an expiration date of 2/XX19, which includes a federal holiday.  The correct expiration date should be 2/XX19. Buyer Comment (2019-05-29): pccd uploaded Reviewer Comment (2019-05-21): Rec'd settlement statement.  Need final PC CD reflecting correct disbursement date, and LOE to the borrower.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

207944367

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure disclosed the lender will not allow the loan to be Assumed however, the Note contains an Assumption Clause.

Reviewer Comment (2019-05-21): Waived at client's request. Buyer Comment (2019-05-20): needs to be waived. This was a system glitch and has now been fixed

05/21/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208014771

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Unable to locate verification of receipt of the secondary appraisal.

Reviewer Comment (2019-05-02): Exception is for the 2nd appraisal dated XX23; the appraisal could not have been received XX13. Seller Comment (2019-05-02): Disagree  Per the Disclosure Tracking in the loan file, the initial appraisal was sent to the borrower on XXXX19.

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

No

208014771

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The CD lists the closing date as XXXXXX and the mortgage was notarized on XXXXXX.

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Safe Harbor QM

Safe Harbor QM

Yes

208016566

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.73300% or Final Disclosure APR of 6.79600% is in excess of allowable threshold of APOR 4.56% + 1.5%, or 6.06000%.  Non-Compliant Higher Priced Mortgage Loan.

Federal Higher-Priced Mortgage Loan - stated APR (6.796%) and audited APR (6.733%) exceed the HPML threshold of 6.06% (1.5% over applicable APOR, 4.56%). Loan does not appear to comply with repayment ability, prepayment penalty, and escrow restrictions and requirements applicable to Federal HPMLs.

Reviewer Comment (2019-09-27): Loan is HPML Compliant. Reviewer Comment (2019-09-27): This exception has been sent to our compliance department for review. Buyer Comment (2019-09-18): Loan is HPML and includes required impounds for HPML loans per closing CD so is compliant per our review.  Please re-review and advise if this condition can be cleared.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016566

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Appraisal Not Obtained Timely)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Appraisal not obtained prior to consummation.

Appraisal report dated is XXXXXX, which is after the subject loan closed on XXXXXX. Subject loan is a non-compliant HPML loan and the appraisal dated after closing does not meet the requirements of TILA HPML Appraisal Rule (Dodd-Frank 2014).

Reviewer Comment (2019-09-27): Waive per client request. Reviewer Comment (2019-09-27): Exception downgraded to EV2-B due to preliminary appraisal delivered 3 day prior to close with revised appraisal provided with no change to appraised value. Reviewer Comment (2019-09-27): This exception has been sent to our compliance department for review. Buyer Comment (2019-09-18): effective date of appraisal is xx.  appraiser delivered appraisal 6/6 , but provided final revisions on xx per attached.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016566

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Verified information per the Final Closing Disclosure provided.

Reviewer Comment (2019-09-03): Waive per client request.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016566

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final CD reflects a closing date of XXXXXX and the loan signed XXXXXX.

Reviewer Comment (2019-09-03): Waive per client request.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Non-Assumability Rider to the Note was not provided at the time of audit review.

Reviewer Comment (2019-09-03): Waive per client request.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

C

A

Non QM

Non QM

Yes

208016567

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Consumer(s) Final CD disclosed Closing Date XXXXXX, however consummation took place on XXXXXX as indicated by wet signature(s).

Reviewer Comment (2019-09-03): Waive per client request.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

C

A

Non QM

Non QM

Yes

208016567

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

File is missing the secondary valuation required for securitization.

Reviewer Comment (2019-09-27): Received a desk review with an inconclusive value and a desk-top review which supports the original appraised value of $xxxx. Buyer Comment (2019-09-24): please see desk review attached Reviewer Comment (2019-09-12): Reviewed comment: "Please disregard upload 9/5/XX .  desk review is pending" Buyer Comment (2019-09-05): Please disregard upload .  desk review is pending. Buyer Comment (2019-09-05): please see appraisal review attached

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

C

A

Non QM

Non QM

No

208016567

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Total cash-out discrepancy.

HUD-1 total cash-out of ___ is greater than Guideline total cash-out of ___.

Borrower received $544,293.02 cash back at closing, which exceeds the Full Doc guideline maximum of $500,000.00. File is missing the lender's approved exception with verified compensating factors to allow the excessive cash out.

Borrower on this Bank Statement  documentation loan has a disposable income of $5,088.84 44.94647% DTI on this Bank Statement documentation loan < 50.00% guideline maximum 31.42857% LTV < 85.00% guideline maximum

Originator Originator Originator

Reviewer Comment (2019-09-12): Lender's exception approval provided allowing cass in hand $546,000.00 Buyer Comment (2019-09-05): please see exception

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

C

A

Non QM

Non QM

No

208016567

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Documentation

Loan is to go in a securitization and secondary valuation does not support the appraised value within a 10% tolerance.  The lower value was not used to calculate LTV.

Reviewer Comment (2019-09-27): Received a desk review with an inconclusive value and a desk-top review which supports the original appraised value of $xxxx.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

C

A

Non QM

Non QM

No

208016568

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final Closing Disclosure said the loan is not assumable. However, according to the Note, it is assumable.

Reviewer Comment (2019-09-03): Waive per client request.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016568

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for Credit Report fee of $1.19 was not provided.

Reviewer Comment (2019-09-04): Waive per client request.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016568

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $51.19 exceeds tolerance of $50.00.  Insufficient or no cure was provided to the borrower.

Appraisal Fee was disclosed as $50.00 on the Initial Loan Estimate dated XXXXXX, but disclosed as $51.19 on the revised Closing Disclosure dated XXXXXX and on the Final Closing Disclosure. Evidence of cure for the increase of $1.19 was not provided.

Reviewer Comment (2019-09-26): AMC received PCCD indicating cure, LOE, Proof of Delivery, and Refund Check. Exception Cleared.

09/26/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

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

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016568

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $51.19 exceeds tolerance of $50.00.  Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2019-09-26): AMC received PCCD indicating cure, LOE, Proof of Delivery, and Refund Check. Exception Cured.

09/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016569

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-09-06): Waive per client request.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208016569

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Borrower is the self-employed owner and XXXXXX  and the borrower's wage income was verified only with paystubs. File is missing the borrower's XX W-2 as required by XXXXXX Full Doc guidelines.

Reviewer Comment (2019-09-27): Received the XX W-2 and lender attestation regarding how the borrower's W--2 wage income has been verified and calculated. Borrower owns a C-Corp and the YTD paystubs support the CPA's letter that annual wages are $xxxx. Buyer Comment (2019-09-12): Borrower owns and operates XXXXXX since 4/XX2010.   She is 100% owner.  Entity files 1120S returns.    During XX borrower paid herself W2 wages from XXXXXX as show on Page 1 of 1120s and 1040s.    XX W2 is attached as requested. Borrower also owns and operates XXXXXX since 7/XX16.   She is 51% owner.   Entity files 1120 returns.  During XX, no W2 wages were paid by XXXXXX as shown on Page 1 of the 1120 returns.   As per the CPA letter, borrower is now paying herself W2 wages through the XXXXXX entity as show by paystubs included in file.    CPA letter verifies that continuation of W2 income though the borrower's other pharmacy operation is possible without negative impact on the business.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016569

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

A XX extension request was provided.

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016570

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

CD closing date XXXX19 signed XXXX19.

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016570

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller Change - Total Payoffs

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether there was a change in the Total Payoffs and Payments.

Final CD reflects, yes, there was a change in payoffs. LE reflects $xxxxx and Final CD reflects $xxxxx, difference only due to LE rounding.

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016570

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

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

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Right to Cancel was executed by the borrowers on XXXXXX. The document date was changed to XXXXXX and the rescission period expiration was changed to XXXXXX with the changes initialed by the borrowers. However, the Final Closing Disclosure disclosed a disbursement date of XXXXXX, which matches the rescission ending date. Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form are required to cure this exception.

Reviewer Comment (2019-09-27): Received the certified final settlement statement to verify the final disbursement date of XXXXXX. Buyer Comment (2019-09-20): please see final ss. loan disbursed on 6/20

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

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

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016570

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Proof that revised appraisal was delivered to borrower was not provided.

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016570

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Total cash-out discrepancy.

HUD-1 total cash-out of ___ is greater than Guideline total cash-out of ___.

Borrowers received $733,316.50 total cash out at closing, which exceeds the Full Doc guideline maximum of $500,000.00. File is missing the lender's approved exception with verified compensating factors to allow the excessive cash out.

29.18% DTI on this Full Doc documentation loan < 50.00% guideline max - 20.82% below program guideline maximum (DTI was calculated using 36 months for asset depletion vs the guideline required 120 months) 215.56 months reserves > 6 months guideline minimum - (reserves include cash out proceeds)

Originator Originator

Reviewer Comment (2019-09-27): Lender approved exception to allow $733,316.50 total cash out at closing, vs the guideline max of $500,000.00.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016570

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower was qualified with monthly asset depletion income of $26,415.00 that included the full balances of 2 IRA accounts however, the borrower is not XXXXXX years-old and XXXXXX Full Doc guidelines allow only 60% of the current balance to be used for depletion. In addition, the depletion income was calculated over 36 months; the guidelines require assets to be depleted over 120 months. The verified asset depletion income is $10,662.19, which results in a DTI of 72.30%.

29.18% DTI on this Full Doc documentation loan < 50.00% guideline max - 20.82% below program guideline maximum (DTI was calculated using 36 months for asset depletion vs the guideline required 120 months) 215.56 months reserves > 6 months guideline minimum - (reserves include cash out proceeds)

Originator Originator

Reviewer Comment (2019-09-27): Lender approved exception to allow the borrower's assets (including cash out proceeds) to be depleted over 36 months vs the guideline required 120 months for asset depletion income. Buyer Comment (2019-09-13): Please see Underwriter Income Calculation attached.   Funds used from retirement accounts have been reduced to 60% prior to being used in Asset Depletion Calculation.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016570

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 72.29565% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Borrower was qualified with monthly asset depletion income of $26,415.00 that included the full balances of 2 IRA accounts however, the borrower is not XXXXXX  and XXXXXX Full Doc guidelines allow only 60% of the current balance to be used for depletion. In addition, the depletion income was calculated over 36 months; the guidelines require assets to be depleted over 120 months. The verified asset depletion income is $10,662.19, which results in a DTI of 72.30%.

Reviewer Comment (2019-09-27): Lender approved exception to allow the borrower's assets (including cash out proceeds) to be depleted over 36 months vs the guideline required 120 months for asset depletion income. Buyer Comment (2019-09-13): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016570

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to a DTI of 72.30%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-27): Lender approved exception to allow the borrower's assets (including cash out proceeds) to be depleted over 36 months vs the guideline required 120 months for asset depletion income. Buyer Comment (2019-09-13): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016570

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 72.30%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-27): Lender approved exception to allow the borrower's assets (including cash out proceeds) to be depleted over 36 months vs the guideline required 120 months for asset depletion income. Buyer Comment (2019-09-13): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016571

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing the full Fraud Report for both borrowers.

Reviewer Comment (2019-09-13): Received

09/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016571

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The ARM Rider indicates Assumable, and the CD reflects not Assumable.

Reviewer Comment (2019-09-03): Waive per client request.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016571

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Subject purchase loan closed with an LTV of 90.00%, which exceeds the Bank Statement guideline maximum LTV of 85.00% for  borrowers with a qualifying FICO score of 640. File is missing a lender approved exception with verified compensating factors to allow the higher LTV.

Borrowers have residual income of $13,017.31 Housing payment history clean for 22 months vs guideline requirement of 12 months

Originator Originator

Reviewer Comment (2019-09-19): Lender approved exception to allow an LTV of 90% which exceeds the guideline max LTV of 85%.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016571

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Per XXXXXX Income Calculation Analysis, the borrowers were qualified with personal bank statement income of $21,369.54 split between both borrowers that was noted to be derived from XXXXXX. However, the file only contains 4 months of statements for this account. The file does contain 12 months of personal statements for XXXXXX, which results in a qualifying income of $12,074.88 and a DTI of 58.42%.

35.15% DTI on this Bank Statement documentation loan < 50.00% guideline max - 14.85% below program guideline maximum Borrowers have residual income of $13,017.31 Housing payment history clean for 22 months vs guideline requirement of 12 months

Originator Originator Originator

Reviewer Comment (2019-09-27): Lender approved exception to allow only 7 months of personal statements for the borrower's bank statement income when the guidelines require 12 months. Reviewer Comment (2019-09-19): Received duplicate April, March and February XX statements and 4 additional statements for XXXXXXl XXXXXX for a total of 7 months personal statements. Guidelines require 12 months. Still missing XXXXXX XXXXXX statements for September XX, August XX, July 2108, June XX, May XX and May XX. Upon receipt of the missing bank statements, additional conditions may apply. Buyer Comment (2019-09-06): XXXXXX Statement have not been used in qualifying income.   See box on right side of UW Income Calculation Analysis.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016571

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 58.41979% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Per XXXXXX Income Calculation Analysis, the borrowers were qualified with personal bank statement income of $21,369.54 split between both borrowers that was noted to be derived from XXXXXX checking account #XXXXXX. However, the file only contains 4 months of statements for this account. The file does contain 12 months of personal statements for XXXXXX, which results in a qualifying income of $12,074.88 and a DTI of 58.42%.

Reviewer Comment (2019-09-27): Lender approved exception to allow only 7 months of personal statements for the borrower's bank statement income when the guidelines require 12 months. Buyer Comment (2019-09-25): Please see response under "Investor qualifying total debt ratio discrepancy" tab. Reviewer Comment (2019-09-19): See comment under DTI exception. Buyer Comment (2019-09-06): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016571

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to missing 12 months of bank statement income documentation as required by the guidelines and a DTI of 58.42%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-27): Lender approved exception to allow only 7 months of personal statements for the borrower's bank statement income when the guidelines require 12 months. Buyer Comment (2019-09-25): Please see response under "Investor qualifying total debt ratio discrepancy" tab. Reviewer Comment (2019-09-19): See comment under DTI exception. Buyer Comment (2019-09-06): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016571

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to missing 12 months of bank statement income documentation as required by the guidelines and a DTI of 58.42%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-27): Lender approved exception to allow only 7 months of personal statements for the borrower's bank statement income when the guidelines require 12 months. Buyer Comment (2019-09-25): Please see response under "Investor qualifying total debt ratio discrepancy" tab. Reviewer Comment (2019-09-19): See comment under DTI exception. Buyer Comment (2019-09-06): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016572

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account Statement Missing

RESPA: Initial escrow account statement was not provided to the borrower.

A copy of an Initial escrow account signed by the Borrower at closing is missing.

Reviewer Comment (2019-08-23): Waive per client request.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016572

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects that assumption is not allowed.

Reviewer Comment (2019-08-23): Waive per client request.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016572

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

The final Closing Disclosure Amount of Non-Escrowed Property Costs over Year 1 disclosed on page 4 is incorrect at $828.  The actual amount is HOA fee of $71 per month x 12 = $852.

Reviewer Comment (2019-10-01): AMC received PCCD correcting non escrowed property costs and LOE. Exception Cured. Buyer Comment (2019-09-27): please see pccd and delivery

10/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016572

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

Index from closing instructions used, 2.632%

Reviewer Comment (2019-08-23): Waive per client request.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016572

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Appraisal 3 day waiver was provided in file however proof that appraisal was delivered to borrower by closing was not provided.

Reviewer Comment (2019-08-23): Waive per client request.

08/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016572

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 54.31133% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower was qualified  a DTI of 24.47% and monthly business bank statement income of $13,306.90 calculated from the P&L statement average. However, the Initial 1003 disclosed income of $6,000.00. XXXXXX business Bank Statement guidelines require the lower of the stated income from the Initial 1003 or the P&L statement average. Using the lower 1003 income results in a DTI of 54.3133%, which exceeds the guideline maximum of 50.00%.

Housing payment history clean for 12 months $28,002 downpayment Borrower has employment stability for 5 years

Originator Originator Originator

Reviewer Comment (2019-09-04): Waived with comp factors noted

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016572

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrower was qualified  a DTI of 24.47% and monthly business bank statement income of $13,306.90 calculated from the P&L statement average. However, the Initial 1003 disclosed income of $6,000.00. XXXXXX business Bank Statement guidelines require the lower of the stated income from the Initial 1003 or the P&L statement average. Using the lower 1003 income results in a DTI of 54.3133%, which exceeds the guideline maximum of 50.00%.

Housing payment history clean for 12 months $28,002 downpayment Borrower has employment stability for 5 years

Originator Originator Originator

Reviewer Comment (2019-09-04): Waived with comp factors noted

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016572

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 54.3133%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-04): Waived with comp factors noted Buyer Comment (2019-08-30): Please see exception approval saved under "Investor qualifying total debt ratio discrepancy" tab.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016572

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to a DTI of 54.3133%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-04): Non-QM Buyer Comment (2019-08-30): Please see exception approval saved under "Investor qualifying total debt ratio discrepancy" tab.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016573

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing the borrower's full Fraud Report.

Reviewer Comment (2019-09-13): Received

09/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final Closing Disclosure disclosed the subject loan is not assumable.

Reviewer Comment (2019-09-04): Waive per client request.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016573

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Verified reserves after closing of 5.44 months are insufficient to cover the guideline required 6 months of reserves. Shortage is due to the earnest money deposit of $20,000.00 was verified with a title company receipt that reflects the funds came from XXXXXX however, the file is missing the 2 months of XXXXXX  account statements to verify the EMD came from the borrower's own funds. Upon receipt of the missing bank statements, additional conditions may apply.

731 representative FICO score > 680 guideline minimum - 51 points above guideline minimum Housing payment history clean for 35 months Borrower has residual income of $12,141.51

Originator Originator Originator

Reviewer Comment (2019-09-27): Lender approved exception to allow 5.44 months reserves vs guideline required 6 months.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___

Borrower was qualified with personal bank statement income derived from XXXXXX brokerage account #8463 however, file is missing the August XX brokerage statement to verify a consecutive 12 months Upon receipt of the missing brokerage statement, additional conditions may apply.

Housing payment history clean for 35 months Borrower has residual income of $12,141.51

Originator Originator

Reviewer Comment (2019-09-27): Lender approved exception to allow only 11 months of bank statements for bank statement income vs guideline required 12 months. Buyer Comment (2019-09-19): please see exception uploaded

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Credit

Income

Document Error

Bank Statements were used for income. All parties listed on each bank account must be included as borrowers on the loan per company guidelines.

Borrower was qualified with personal bank statement income from a joint XXXXXX  brokerage account however, the joint account holder is not a borrower on the subject loan as required by XXXXXX personal Bank Statement guidelines.

731 representative FICO score > 680 guideline minimum - 51 points above guideline minimum Housing payment history clean for 35 months Borrower has residual income of $12,141.51

Originator Originator Originator

Reviewer Comment (2019-09-27): Lender approved exception to allow the use of a joint brokerage account to be used for bank statement income when there's only 1 borrower on the loan. XXXXXX guidelines require all joint account holders to be on the loan. Buyer Comment (2019-09-19): exception

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Missing Document: Credit Letter of Explanation (LOE) not provided

File is missing a detailed letter of explanation from the borrower for the use of a XXXXXX brokerage account for the receipt of business income,and further explanation of whether the business has business bank accounts, as required by XXXXXX Approval condition #201.

Reviewer Comment (2019-09-27): Received the borrower's explanation for the receipt of business income into a joint brokerage account vs business income being deposited to a business account. Buyer Comment (2019-09-19): please see loes uploaded

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Large deposits were not sourced and/or letter of explanation was not provided.

File is missing evidence to verify the deposits into the XXXXXXbrokerage account are business income. File is also missing verification of what percentage of the deposits belong to the non-borrowing spouse, as required by XXXXXX Approval condition #202.

Reviewer Comment (2019-09-27): Received borrower's explanation regarding the deposits into the joint brokerage account are distributions from the borrower's business. Buyer Comment (2019-09-19): please see loes

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

The borrower's departure residence was retained as a rental property however, the file is missing all property expense verifications (mortgage statement, real estate tax verification a hazard insurance policy). Upon receipt of the missing property expense verifications, additional conditions may apply.

Reviewer Comment (2019-09-27): Received the signed lease agreement for the borrower's departure residence.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower was qualified with the vacancy factor using $3,500.00 month in rent for the property at XXXXXX  however, the file is missing the current and fully executed lease agreement. This rental income has therefore been excluded resulting in a DTI of 56.00%, which exceeds the guideline maximum DTI of 50.00%. Upon receipt of the missing current and fully executed lease agreement, additional conditions may apply.

Reviewer Comment (2019-09-27): Received the signed lease agreement for the borrower's departure residence.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 56.00076% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Borrower was qualified with the vacancy factor using $3,500.00 month in rent for the property at XXXXXX  however, the file is missing the current and fully executed lease agreement. This rental income has therefore been excluded resulting in a DTI of 56.00%, which exceeds the guideline maximum DTI of 50.00%. Upon receipt of the missing current and fully executed lease agreement, additional conditions may apply.

Reviewer Comment (2019-09-27): Received the signed lease agreement for the borrower's departure residence.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016573

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to missing a lease agreement to verify rental income and a DTI of 56.00%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-27): Received the signed lease agreement for the borrower's departure residence. Buyer Comment (2019-09-11): Please see response under "General ATR Provision" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016573

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to missing a lease agreement to verify rental income and a DTI of 56.00%, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-27): Received the signed lease agreement for the borrower's departure residence. Buyer Comment (2019-09-11): Please see response under "General ATR Provision" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016574

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Missing Document: Security Instrument not provided

File is missing the Deed of Trust and all applicable Riders. Upon receipt of the missing Deed of Trust and all applicable Riders, additional conditions may apply.

Reviewer Comment (2019-09-04): Received the signed and notarized Deed of Trust and all applicable Riders.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

D

A

C

B

A

A

Non QM

Non QM

No

208016574

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Reviewer Comment (2019-09-27): Received the Short Form Title Policy.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

D

A

C

B

A

A

Non QM

Non QM

No

208016574

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final Closing Disclosure does not allow assumption but the Note reflects assumption language.

Reviewer Comment (2019-08-27): Waive per client request.

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

208016574

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Hazard Insurance Dec Page reflects a premium of $701.90 per year and the final Closing Disclosure reflects $713.90 per year.

Reviewer Comment (2019-08-27): Waive per client request.

08/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

208016574

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Non-Escrowed Property Costs over Year 1 of $5,352.00. Non-Escrowed Property Costs are $443.00 per month, which equates to calculated Escrowed Property Costs over Year 1 of $5,316.00. Letter of Explanation to the borrower and Corrected Closing Disclosure are required to cure this exception.

Reviewer Comment (2019-09-19): AMC received PCCD correcting non escrowed property costs and LOE. Exception Cured. Buyer Comment (2019-09-18): Please see pccd and delivery

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

D

B

D

A

C

B

A

A

Non QM

Non QM

Yes

208016574

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Right of Rescission Timing - Note Date used as Transaction Date

Unable to conclusively determine date of consummation. Note date used as transaction date for purposes of determining compliance with rescission timing requirements

Missing Mortgage to determine Notary date.

Reviewer Comment (2019-10-23): Received the Deed of Trust and all applicable riders. Reviewer Comment (2019-10-23): Reopened exception per XXXXX request. Reviewer Comment (2019-08-27): Waive per client request.

10/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

D

A

C

B

A

A

Non QM

Non QM

No

208016574

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Title Commitment reflects a Proposed Policy Amount of $600,000.00, which is insufficient to cover the subject loan amount of XXXXXX Final Title Policy was not provided in the imaged file.

Reviewer Comment (2019-09-27): Received the Short Form Title Policy which verifies a policy amount of $xxxx Buyer Comment (2019-09-20): please see final title policy

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

D

B

D

A

C

B

A

A

Non QM

Non QM

No

208016575

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure disclosed that assumption is not allowed.

Reviewer Comment (2019-09-28): Waive per client request.

09/28/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208016576

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

FEMA Disaster Issue: The most recent valuation inspection is dated prior to the most recent FEMA disaster.

Most Recent Valuation Inspection Date: ___                  Disaster End Date: ___ Disaster Name: ___ Disaster Declaration Date: ___

The most recent property inspection date of XXXXXX is prior to the Disaster Declaration Date of XXXXXX.  A post disaster inspection report was not provided.

Reviewer Comment (2019-06-17): Received post-disaster inspection, which verifies no damage to the subject property in the last FEMA Disaster. Reviewer Comment (2019-06-14): Disaster inspection will be ordered by diligence vendor & exception updated upon receipt. Reviewer Comment (2019-05-23): Rec'd PDI.  Appraiser did not provide the Date of Inspection.

06/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016576

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Per the final loan application, the borrower had a base income of $8,936.83 per month and "other types of income" in the amount of $4,270.83.  The paystubs provided reflects the monthly income of $8,936.86; however, there is no documentation in the file reflecting what other types of income the $4,270.83 is or where it is derived from.  The calculated DTI of 81.2241% exceeds the guideline maximum of 50%.

Housing payment history clean for 83 months Borrower has residual income of $6,771.01 36.31 months reserves > 6 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-09-27): Lender approved exception to allow a DTI up to 55, which covers the Final DTI of 51.74%. Buyer Comment (2019-09-20): please see upload Reviewer Comment (2019-09-20): Per XXXXXX income worksheet, borrower was qualified with a DTI of 54.79%. Received lender exception to allow cash out proceeds to be used for asset depletion. This reduced the DTI to 51.74%. A lender approved exception with verified compensating factors related to the borrower's ability to repay is required to waive this exception. Reviewer Comment (2019-08-07): This exception has been reviewed by management and the pier diem income is being allowed for this loan only. This reduced the DTI to 59.50%. A client approved exception was uploaded however, the exception reads "Ok to use cash out for reserves." The borrower was qualified with asset depletion income, so the exception must be revised to allow cash out for asset depletion. Once we receive the corrected client approval, this will reduce the DTI to around 51.74%. A separate client approved exception with verified compensating factors related to the borrower's ability to repay to allow the DTI above 50% is required to waive this exception. Buyer Comment (2019-07-23): due to the borrowers position as a state senator the per diem income was included in the DTI calculation.  It is a regular part of his compensation /income based on his position. Reviewer Comment (2019-06-26): The K-1 provided cannot clear this exception due to borrower was qualified with unallowed per diem pay and DTI remains at 81.2241%. Reviewer Comment (2019-05-23): Rec'd K-1. Reviewer Comment (2019-05-23): Rec'd documentation to reflect the $4,200 additional income is per diem.  Per diem is considered a reimbursement to cover additional expenses incurred by an employee, not actual income available as repayment income for monthly liabilities and housing.  Additionally, guidelines state that unacceptable sources of income include income not reported to the IRS.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016576

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

AUS Findings: All conditions were not met

Various required credit documentation was not provided.  Exceptions for missing documentation have been added individually.

Reviewer Comment (2019-05-14): Not AUS.  Duplicate exception.

05/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016576

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower: XXXXXX

Borrower's XX Schedule E shows partnerships in two businesses.  A schedule K-1 was provided to evidence 0% ownership in the first business and there are no losses and we are not using income, therefore no further explanation or documentation is required.  No documentation was provided for the second partnership evidencing < 25% ownership, therefore a 1065 will need to be reviewed for any potential losses or a Schedule K1 will need to be provided to evidence < 25% ownership.

Reviewer Comment (2019-05-23): Rec'd K-1.

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016576

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

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

Credit Report: Original // Borrower: XXXXXX

The fraud report identifies a potential undisclosed REO in xxxxx, AZ xxxxx.  No explanation or other documentation was provided to address this property.

Reviewer Comment (2019-05-23): All red flags addressed. Buyer Comment (2019-05-21): SEE ATTACCHED

05/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

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

Due to DTI exceeding 50%, the loan is an ATR risk.

Reviewer Comment (2019-09-27): Lender approved exception to allow a DTI up to 55, which covers the Final DTI of 51.74%. Buyer Comment (2019-09-20): please see upload Reviewer Comment (2019-09-20): See comment under DTI exceptions. Buyer Comment (2019-08-28): please see upload Reviewer Comment (2019-08-07): See comment under DTI exceptions. Buyer Comment (2019-07-23): due to the borrowers position as a state senator the per diem income was included in the DTI calculation.  It is a regular part of his compensation /income based on his position. exception attached

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Based on the loan failing one or more guideline components, the loan is at ATR risk.  DTI exceeds 50%.

Reviewer Comment (2019-06-26): Upon rerun of compliance, exception was cleared.

06/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Note contains assumption language, however, the final CD discloses the loan as non-assumable.  No additional disclosures provided that override the assumption language on the note.

Reviewer Comment (2019-04-26): Okay to waive per client.

04/26/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  XXXXXX disclosed a Closing Date that did not match the actual date of consummation. (Final/ XXXXXX)

The final CD discloses the closing date as XXXXXX, however, the loan was consummated on XXXXXX.

Reviewer Comment (2019-07-09): Waiving at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of $12,347.88 on Final Closing Disclosure provided on XXXXXX not accurate. (Final/XXXXXX)

The hazard insurance policy provided evidences a monthly premium of $217.91, however, only $195.01 was included in the DTI and disclosed amounts for hazard.

Reviewer Comment (2019-07-18): Letter of Explanation & Corrected Closing Disclosure provided.

07/18/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Reviewer Comment (2019-08-05): Received the final closing statement to verify the disbursement date of XXXXXX. Buyer Comment (2019-07-23): final settlement statement Reviewer Comment (2019-07-18): Please provide Final Settlement Statement to confirm disbursement date Buyer Comment (2019-07-17): loan disbursed as shown on the PCCD

08/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Circuit 2, 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.

Title evidences this transaction is a same lender refinance, however, form H-8 was used for disclosing the RTC instead of the correct H-9 form for same lender refinances.

Reviewer Comment (2019-07-09): Waiving at client request, EV2

07/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 81.22410% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 81.22410% significantly exceeds the guideline maximum of 50.00%.  Per the final loan application, the borrower had a base income of $8,936.83 per month and "other types of income" in the amount of $4,270.83.  The paystubs provided reflects the monthly income of $8,936.86; however, there is no documentation in the file reflecting what other types of income the $4,270.83 is or where it is derived from.

Reviewer Comment (2019-09-20): Received lender exception to allow cash out proceeds to be used for asset depletion. Buyer Comment (2019-08-28): please see upload Reviewer Comment (2019-08-07): This exception has been reviewed by management and the pier diem income is being allowed for this loan only. This reduced the DTI to 59.50%. A client approved exception was uploaded however, the exception reads "Ok to use cash out for reserves." The borrower was qualified with asset depletion income, so the exception must be revised to allow cash out for asset depletion. Once we receive the corrected client approval, this will reduce the DTI to around 51.74%. A separate client approved exception with verified compensating factors related to the borrower's ability to repay to allow the DTI above 50% is required to waive this exception. Buyer Comment (2019-07-25): please see comments regarding income exception Reviewer Comment (2019-06-03): Updated from: Ability to Repay (Dodd-Frank XX): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 81.22410% significantly exceeds the guideline maximum of 50.00%.  (DTI Exception cannot be compensated to a lower grade.) Reviewer Comment (2019-05-23): Rec'd documentation to reflect the $4,200 additional income is per diem.  Per diem is considered a reimbursement to cover additional expenses incurred by an employee, not actual income available as repayment income for monthly liabilities and housing.  Additionally, guidelines state that unacceptable sources of income include income not reported to the IRS.

09/20/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016576

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 51.73861% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Received lender exception to allow cash out proceeds to be used for asset depletion. This reduced the DTI to 51.74%.

Housing payment history clean for 83 months Borrower has residual income of $6,771.01 36.31 months reserves > 6 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-09-27): Lender approved exception to allow a DTI up to 55, which covers the Final DTI of 51.74%. Buyer Comment (2019-09-20): please see exception allowing dti up to 55% Reviewer Comment (2019-09-20): Per XXXXXX income worksheet, borrower was qualified with a DTI of 54.79%. Received lender exception to allow cash out proceeds to be used for asset depletion. This reduced the DTI to 51.74%. A lender approved exception with verified compensating factors related to the borrower's ability to repay is required to waive this exception.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Unacceptable assets were used for closing or reserves.

Lender acknowledged exception to allow Down payment and closing costs paid with borrower's business funds vs. program requirement that business funds used for down payment and or closing costs must be transferred to borrower's personal account.  Approved Lender Exception in file.

Borrower has been self-employed for the past 25 years as XXXXXX Borrower has 1 open mortgage paid as agreed since inception VVVVVV.  No public records. Reserves are 9.33 months, 5.33 months > program requirement of 4 months. Credit score is 733, 53 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-05): Client has elected to waive this exception based on compensating factors.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Missing borrower signed Ability to Repay Attestation.

Reviewer Comment (2019-09-09): Borrower Ability to Repay Attestation provided

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

DTI of 43.2894% exceeds max of 43% allowed per guides.  Lender did not include all taxes in DTI.

Borrower has been self-employed for the past 25 years as XXXXXX Borrower has 1 open mortgage paid as agreed since inception VVVVVV.  No public records. Reserves are 9.33 months, 5.33 months > program requirement of 4 months. Credit score is 733, 53 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-19): Client elects to waive the exception with verified compensation factors Reviewer Comment (2019-09-06): No new information was provided ion trailing docs.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing August XX Bank Statement used for income qualification.

Reviewer Comment (2019-09-06): August XX Bank Statement provided.

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Loan failed ATR due to DTI of 43.289% exceeding max allowed of 43%.  Lender did not include all property taxes into DTI calculation.

Reviewer Comment (2019-09-19): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-09-18): Please see uploaded exception Reviewer Comment (2019-09-06): No new information was provided ion trailing docs. Buyer Comment (2019-09-05): xxxxPlease see uploaded documents

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Loan failed ATR due to DTI of 43.289% exceeding max allowed of 43%.  Lender did not include all property taxes into DTI calculation.

Reviewer Comment (2019-09-19): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-09-18): Please see uploaded exception Reviewer Comment (2019-09-06): No new information was provided ion trailing docs. Buyer Comment (2019-09-05): xxxxx

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 43.28994% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Loan failed ATR due to DTI of 43.289% exceeding max allowed of 43%.  Lender did not include all property taxes into DTI calculation.

Borrower has been self-employed for the past 25 years as XXXXXX Borrower has 1 open mortgage paid as agreed since inception VVVVVV.  No public records. Reserves are 9.33 months, 5.33 months > program requirement of 4 months. Credit score is 733, 53 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-19): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-09-18): Please see uploaded exception Reviewer Comment (2019-09-06): No new information was provided ion trailing docs. Buyer Comment (2019-09-05): 1907020243

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

Missing evidence borrower was provided a copy of the List of Homeownership Counseling Organizations at time of application.

Reviewer Comment (2019-09-09): Initial disclosure provided.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Missing evidence borrower was provided a copy of the Home Loan Toolkit at time of application.

Reviewer Comment (2019-09-09): Initial disclosure provided.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $252.00 exceeds tolerance of $228.00 plus 10% or $250.80.  Sufficient or excess cure was provided to the borrower at Closing.

Total increase of fees in the amount of $252 exceeded the max 10% increase of $250.80.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $12.00 exceeds tolerance of $10.00.  Sufficient or excess cure was provided to the borrower at Closing.

Initial LE reflected Flood Cert fee of $10.00  increased to $12.00 without a valid change circumstance. Tolerance exceeded. No evidence cure was provided to borrower.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.  CD is blank in this section. Amount to cure is $1,819.13. No indication that cure was provided to borrower.

Reviewer Comment (2019-09-10): Tolerance exceptions are addressed. Exception Cleared.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $252.00 exceeds tolerance of $228.00 plus 10% or $250.80.  Insufficient or no cure was provided to the borrower.

en Percent Fee Tolerance exceeded. Total amount of $252.00 exceeds tolerance of $228.00 plus 10% or $250.80. Insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-09-10): AMC reviewed exception. Upon further review exception may be cleared.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Discount Points.  Fee Amount of $1,819.13 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Discount Points fee increased $1,819.13 without a valid change circumstance. Tolerance exceeded. No evidence cure was provided to borrower.

Reviewer Comment (2019-09-10): AMC received XX15 COC. Exception Cleared.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Flood Certification (Life Of Loan).  Fee Amount of $12.00 exceeds tolerance of $10.00.  Insufficient or no cure was provided to the borrower.

Flood Certification Fee  increased $12.00 without a valid change circumstance. Tolerance exceeded. No evidence cure was provided to borrower.

Reviewer Comment (2019-09-10): AMC reviewed exception. Upon further review exception may be cleared.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016648

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Timing

Truth in Lending Act (2015): Creditor or broker did not provide the Home Loan Toolkit Disclosure to applicant within 3 business days of application.

Provide initial disclosure.

Buyer Comment (2019-09-18): XXXXXX has elected to waive

09/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016650

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Missing signed borrower attestation as required per guidelines.

Reviewer Comment (2019-09-19): AMC has received the ATR attestation completed and signed.

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016650

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Missing evidence borrower received initial CD a minimum of 3 days prior to closing.

Reviewer Comment (2019-09-17): AMC recieved XX19 CD received the same day. Exception Cleared.

09/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016651

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Subject was purchased 86 days ago on XXXX19 vs program requirement of 90 days ownership.   Allow rents paid in cash of $18K per month vs program requirement to provide copy of leases and 3 months rent receipts (Note:  Property currently listed for sale on XXXX19)

No public records Self-employed for the past 25 years as owner of XXXXXX DTI is 14.832%, 35.168% < program max of 50%

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-05): Client has elected to waive this exception based on compensating factors.

09/05/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

A

A

A

A

N/A

N/A

No

208016651

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Aged document: Primary Valuation is older than guidelines permit

- ___

Lender approved exception to utilize dated appraisal for purchase of property

No public records Self-employed for the past 25 years as owner of XXXXXX DTI is 14.832%, 35.168% < program max of 50%

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-05): Client has elected to waive this exception based on compensating factors.

09/05/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

A

A

A

A

N/A

N/A

No

208016651

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Maximum Loan Amount discrepancy.

Note loan amount of ___ is greater than Guideline maximum loan amount of ___.

Lender exception granted for loan amount exceeding $1,000,000

No public records Self-employed for the past 25 years as owner of XXXXXX DTI is 14.832%, 35.168% < program max of 50%

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-05): Client has elected to waive this exception based on compensating factors.

09/05/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

A

A

A

A

N/A

N/A

No

208016651

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

No public records Self-employed for the past 25 years as owner of XXXXXX DTI is 14.832%, 35.168% < program max of 50%

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-09-06): See attached Exception

09/09/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

A

A

A

A

N/A

N/A

No

208016651

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Combined loan to value discrepancy.

Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___.

No public records Self-employed for the past 25 years as owner of XXXXXX DTI is 14.832%, 35.168% < program max of 50%

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-09): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-09-06): See attached Buyer Comment (2019-09-06): See attached Exception.

09/09/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

A

A

A

A

N/A

N/A

No

208016652

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-06): XXXXXX has elected to waive this exception.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208016652

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-09-06): XXXXXX has elected to waive this exception.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208016653

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 7.91930% or Final Disclosure APR of 7.93300% is in excess of allowable threshold of APOR 4.30% + 1.5%, or 5.80000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-09-09): Initial disclosure provided.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

A

A

C

A

A

A

Non QM

Non QM

No

208016653

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

Reviewer Comment (2019-09-06): AMC received the homeownership counseling disclosure dated 6/XX19.

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

A

A

C

A

A

A

Non QM

Non QM

No

208016653

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Status

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.

Reviewer Comment (2019-09-09): CHARM booklet provided.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

208016653

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Timing

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-09-09): Initial disclosure provided.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

A

A

C

A

A

A

Non QM

Non QM

Yes

208016653

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Timing

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure within 3 days of the loan application date.

Reviewer Comment (2019-09-09): Initial disclosure provided.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

A

A

A

C

A

A

A

Non QM

Non QM

No

208016653

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Servicing Disclosure missing

Reviewer Comment (2019-09-09): Initial disclosure provided.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Good faith redisclosure

C

A

A

A

C

A

A

A

Non QM

Non QM

Yes

208016653

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Initial CD Issued less than 6 days prior to closing and received by the borrower less than 3 business days prior to closing.

Reviewer Comment (2019-09-09): AMC received XX14 CD. Exception Cleared.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

208016653

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $4,497.25 may be required.

LE missing from the file

Reviewer Comment (2019-09-09): AMC received LEs. Exception Cleared.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

A

A

A

C

A

A

A

Non QM

Non QM

No

208016654

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

Disclosure was provided to the borrower on XXXX19 vs. at time of application on XXXX19.

Buyer Comment (2019-09-04): XXXXXX has elected to waive

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016654

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $8,987.00 and disclosure timing violations.

Missing borrower E-sign consent form.

Reviewer Comment (2019-09-04): E-consent provided

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016654

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final CD does not reflect an amount by which the fees exceeded the legal limit.

Reviewer Comment (2019-09-04): E-consent provided

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016654

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Initial LE was electronically signed yet borrower E-sign Consent Disclosure missing from loan file.

Reviewer Comment (2019-09-04): E-consent provided

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016654

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Origination Fee.  Fee Amount of $2,505.00 exceeds tolerance of $2,500.00.  Insufficient or no cure was provided to the borrower.

Initial LE reflected a Loan Origination Fee of $2,500 yet the final CD shows a charge in the amount of $2,505.  Although a valid change of circumstance is in the file, the initial LE was e-signed and Borrower E-sign Consent form is missing from the loan file.

Reviewer Comment (2019-09-04): E-consent provided

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016654

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 5.71930% or Final Disclosure APR of 5.74800% is in excess of allowable threshold of Prime Mortgage Market Rate 3.75000 + 1.75%, or 5.50000%.  Compliant SubPrime Loan.

Buyer Comment (2019-09-04): XXXXXX has elected to waive

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016655

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

1003 Error: Originator Application Date was not provided

Missing originator's initial application.

Reviewer Comment (2019-09-11): Originator's initial application provided. Buyer Comment (2019-09-10): 1003 uploaded.

09/11/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

N/A

N/A

No

208016655

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Missing evidence of annual insurance for xxxxx and missing evidence of annual taxes and insurance for xxxxx.

Reviewer Comment (2019-09-11): Documentation provided. Buyer Comment (2019-09-10): Insurance for XXXXXX and insurance and taxes for XXXXXX uploaded.

09/11/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

N/A

N/A

No

208016655

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure disclosure to applicant within three (3) business days of application or determination of first lien status.

Buyer Comment (2019-09-10): XXXXXX has elected to waive this exception.

09/10/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

N/A

N/A

No

208016655

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: Closing Disclosure is incomplete

HUD-1 Closing statement incomplete; missing pages 2 & 3

Reviewer Comment (2019-09-18): Pages 2 and 3 provided. Buyer Comment (2019-09-17): Complete HUD-1 for XXXXXX uploaded. Reviewer Comment (2019-09-16): Still need pages 2 and 3 for XXXXXX Reviewer Comment (2019-09-11): Wrong property closing statement provided in trailing docs. Provide closing statement for XXXXXX all pages.

09/18/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

N/A

N/A

No

208016655

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Missing CD or HUD-1 on concurrent closing for loan xxxxx to show PITI payment

Reviewer Comment (2019-09-16): Revised 1008 provided with correct loan #. Buyer Comment (2019-09-16): The loan number is missing a digit. The correct loan# is xxxx, this loan is in your portal. Revised 1008 uploaded. Reviewer Comment (2019-09-11): Per 1008, "Loan to close concurrently with loan # xxxx, what property is this for? Buyer Comment (2019-09-10): HUD-1 from concurrent loan uploaded.

09/16/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

N/A

N/A

No

208016655

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Reviewer Comment (2019-09-11): Documentation provided. Buyer Comment (2019-09-10): Mortgage statements which show taxes and insurance for XXXXXX uploaded.

09/11/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

N/A

N/A

No

208016655

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Buyer Comment (2019-09-10): XXXXXX has elected to waive this exception.

09/10/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

N/A

N/A

No

208016656

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-06): XXXXXX has elected to waive this exception.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208016657

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Reviewer Comment (2019-09-16): Final Title Policy with corrected vesting.

09/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016657

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-09-12): XXXXXX has elected to waive this exception

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016657

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-16): XXXXXX has elected to waive this exception. Reviewer Comment (2019-09-12): Unable to clear or remove EV-2 compliance exceptions. Buyer Comment (2019-09-12): Duplicate exception: Please remove

09/16/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016657

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Closing / Title

Title Error: Title vesting does not concur with deed

Title commitment reflects XXXXXX vs XXXXXX

Reviewer Comment (2019-09-16): Final Title Policy with corrected vesting. Buyer Comment (2019-09-13): Uploaded For Review: Corrected Title

09/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016657

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy Coverage is less than Original Loan Amount.

Reviewer Comment (2019-09-16): Final Title Policy with corrected Loan Amount provided. Buyer Comment (2019-09-13): Uploaded For Review: Corrected Title

09/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016659

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Loan File

Missing Document: Hazard Insurance Policy not provided

Hazard Insurance Policy not provided

Reviewer Comment (2019-09-05): HOI binder provided. Buyer Comment (2019-09-04): HOI uploaded for review.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Non QM

Non QM

No

208016659

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Hazard Insurance policy not provided

Reviewer Comment (2019-09-05): HOI binder provided. Buyer Comment (2019-09-04): HOI uploaded for review.

09/05/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Non QM

Non QM

No

208016659

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $519.00 exceeds tolerance of $495.00.  Sufficient or excess cure was provided to the borrower at Closing.

09/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Final CD evidences Cure

C

A

C

A

A

A

A

A

Non QM

Non QM

Yes

208016659

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

Hazard Insurance Error: Subject hazard insurance policy expiration date is missing from evidence of insurance.

HOI binder does not indicate an expiration date.

Reviewer Comment (2019-09-06): Corrected HOI policy provided. Buyer Comment (2019-09-05): Uploaded For Review: HOI

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Non QM

Non QM

No

208016659

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

Hazard Insurance Error: Subject hazard insurance policy number is missing from evidence of insurance.

HOI binder does not indicate policy #.

Reviewer Comment (2019-09-06): Corrected HOI policy provided. Buyer Comment (2019-09-05): Uploaded For Review: HOI

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

A

C

A

A

A

A

A

Non QM

Non QM

No

208016661

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) New York Subprime Loan (Counseling Disclosure Not Provided at Application but within Three Days)

XXXXXX Subprime Loan: Counseling Disclosure not provided to borrower at the time of application, but within three days of application.

The SubPrime Counseling Disclosure was provided to the borrower on XXXX19 vs. at time of application on XXXX19.

Buyer Comment (2019-09-09): XXXXXX has elected to waive

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208016661

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 6.66620% or Final Disclosure APR of 6.70600% is in excess of allowable threshold of Prime Mortgage Market Rate 3.75000 + 1.75%, or 5.50000%.  Compliant SubPrime Loan.

Buyer Comment (2019-09-09): XXXXXX has elected to waive

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Employment Error: Employment job title not provided.

-

Employment job title for XXXX was not provided.

Reviewer Comment (2019-09-11): Agree with lender. Borrower was XXXX at prior job per CBR. Buyer Comment (2019-09-10): Please see In file credit confirming that borrower was a check @ prior job. In addition, see last  page  of Full factual which also confirms the same information. Reviewer Comment (2019-09-10): An exception is in file to allow 18 months self-employment versus guideline requirement of 24 months self-employment. The exception description states that the borrower has been in the XXXX industry for over 10 years working as a XXXX. The final 1003 provided is incomplete due to missing the full pages. Is it possible that the information was provided on the final 1003? Provide a complete copy of the final 1003. If the employment information is not included, provide a copy of the document used by the lender on the exception approval. Buyer Comment (2019-09-09): In addition, there is an exception approval for 18 months self employment with prior job not being considered at all. Buyer Comment (2019-09-09): Please escalate:  This was a prior position.

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-09): XXXXXX has elected to waive this exception

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: Note - Subject Lien is incomplete

Note is cut off on page 1, missing the margin for this adjustable rate

Reviewer Comment (2019-09-09): AMC received the complete Note including the margin. Buyer Comment (2019-09-09): Uploaded For Review: Clear Copy of Note

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to all borrower having been int he restaurant industry for over 10 years working as a XXXX since XXXX (18 months)  vs program requirement that at least one borrower must have been continually self employed for two years.

Perfect credit history since inception of earliest account opened XXXXXX. No public records 37.00974% DTI on this Alt documentation loan < 50% guideline max - 12.9026% below program guideline maximum Borrower has been in the same line of business for the past 11 years XXXXXX Reserves are 5.45  months, 2.45 month > program requirement of 3 months FICO Score 743, 103 points > program requirement of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-06): Client has elected to waive this exception based on compensating factors.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

No Housing History or Less Than 12 Months Verified. 6 Months reserves required per guidelines. Review data and set applicable exception.

Lender acknowledged exception to allow borrower with VOR paid as agreed from XXXX17 to XXXX19 and living rent free with parents from XXXX19 to current vs. program requirement to verify the last 12 month housing history.

Perfect credit history since inception of earliest account opened XXXXXX. No public records 37.00974% DTI on this Alt documentation loan < 50% guideline max - 12.9026% below program guideline maximum Borrower has been in the same line of business for the past 11 years XXXXXX Reserves are 5.45  months, 2.45 month > program requirement of 3 months FICO Score 743, 103 points > program requirement of 640

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-06): Client has elected to waive this exception based on compensating factors.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Missing Document: Asset Documentation not provided

Missing FXXXXXX account for XXXXXX month of XXXXXX; missing page 5 of XXXX18 statement; missing page 5 of XXXX18 statement

Reviewer Comment (2019-09-12): June XX Statement provided with updated income worksheet. Buyer Comment (2019-09-11): Uploaded For Review: June XX Business Bank statement Reviewer Comment (2019-09-10): Missing XXXXXX statement for XXXXXX. Per guidelines, bank statements to be for the 12-month period preceding the month of the Borrower's Initial Application. Application date is XXXXXX. All missing pages provided. Buyer Comment (2019-09-09): Uploaded For Review- July page 5 and September page 5

09/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing June XX

Reviewer Comment (2019-09-12): June XX Statement provided with updated income worksheet. Buyer Comment (2019-09-11): Uploaded For Review: June Business Bank Statement and corrected income WS Reviewer Comment (2019-09-10): Missing XXXXXX statement for XXXXXX. Per guidelines, bank statements to be for the 12-month period preceding the month of the Borrower's Initial Application. Application date is XXXXXX. Condition remains. Buyer Comment (2019-09-09): Please note: Figure noted on Income WS for June XX was deposits reflected on June XX Business Checking account. See attached with Highlighted areas. 12 months were covered for income calculation.

09/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Reviewer Comment (2019-09-10): Appraisal provided at closing. Waiver in file. Buyer Comment (2019-09-09): Uploaded For Review: Appraisal Confirmation

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-09-10): Appraisal provided at closing. Waiver in file. Buyer Comment (2019-09-09): This is a duplicate, please delete.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016662

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.  CD is blank in this section. Amount to cure is $1,093.68. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-09-16): Tolerance exceptions are addressed. Exception Cleared. Buyer Comment (2019-09-13): PCCD Docs uploaded for review. Reviewer Comment (2019-09-12): Zero tolerance exception for survey fee is still open. Buyer Comment (2019-09-12): Uploaded For Review: Attestation

09/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208016662

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $1,093.68 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

survey Fee increased $1093.68 without a valid change circumstance. Tolerance exceeded. No evidence in file that cure provided to borrower.

Reviewer Comment (2019-09-16): AMC received PCCD correcting fee placement and LOE. Exception Cured. Buyer Comment (2019-09-13): Uploaded For Review: PCCD-LOX-Label Reviewer Comment (2019-09-13): Please provide a corrected CD moving the fee to section C and an LOE to cure. Reviewer Comment (2019-09-13): The survey on this CD was added to section B, Services the Borrower did not Shop For. PCCD with the fee moved to section C along with a LOE needed in order to use the attestation to clear. Reviewer Comment (2019-09-12): Survey Fee was disclosed in Section B as a non-shoppable fee required by Lender.  A valid COC is needed or a refund is due. Buyer Comment (2019-09-12): Uploaded For Review: Attestation

09/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208016664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-11): XXXXXX has elected to waive

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208016664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $1,619.12 exceeds tolerance of $452.62 plus 10% or $497.88.  Sufficient or excess cure was provided to the borrower at Closing.

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208016664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $710.00 exceeds tolerance of $680.00.  Sufficient or excess cure was provided to the borrower at Closing.

Sufficient or excess cure was provided to the borrower at Closing.

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208016664

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $344.50 exceeds tolerance of $269.50.  Sufficient or excess cure was provided to the borrower at Closing.

Sufficient or excess cure was provided to the borrower at Closing.

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208016665

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Rate Spread Threshold Test Compliant

XXXXXX Rate Spread Home Loan: APR on subject loan of 8.19270% or Final Disclosure APR of 8.20500% is in excess of allowable threshold of APOR 4.13% + 1.5%, or 5.63000%.  Compliant Rate Spread Home Loan.

Buyer Comment (2019-09-09): XXXXXX has elected to waive this exception

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016665

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

LO compensation documentation was not present in the file

Buyer Comment (2019-09-09): XXXXXX has elected to waive this exception

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016665

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Documented qualifying Assets for Closing of  ___ is less than Cash From Borrower ___.

Missing CPA confirmation that use of business funds for closing would not have a financial impact. No other assets documented in file.

Reviewer Comment (2019-09-09): Guidelines waive cash flow analysis or CPA letter for LTVs of 90% or less. If funds transferred from a business or brokerage account are included in Down Payment and Closing Cost Funds, then Lender's must adhere to Fannie Mae's requirements for evaluating large deposits into the Borrowers' business accounts Buyer Comment (2019-09-09): Please see GUIDELINES BUSINESS FUNDS FOR CLOSING for LTVs 90% or less CPA letter is not required

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016666

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Initial LE was electronically delivered and signed by borrower on XXXX19 yet E-Sign Consent was signed by the borrower on XXXX19.

Reviewer Comment (2019-09-09): AMC received XXXXXX. Exception Cleared. Buyer Comment (2019-09-06): Please see Econsent Accepted - reflects Econsent was sent and accepted on 7/15

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016666

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Esign Consent Agreement Timing

ESIGN Act - Loan Estimate provided on XXXXXX was electronically provided prior to borrower's consent to receive electronic disclosures.  Disclosure will not be used to rebaseline for tolerance purposes and may result in disclosure timing violations.

Initial LE dated XXXX19 was electronically signed by the borrower on XXXX19 yet E-Sign Consent Disclosure was signed by the borrower on XXXX19.

Reviewer Comment (2019-09-09): AMC received XXXXXX. Exception Cleared. Buyer Comment (2019-09-06): Please see Econsent Accepted - reflects Econsent was sent and accepted on 7/15

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016666

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing LO Compensation Disclosure.

Buyer Comment (2019-09-04): XXXXXX has elected to waive this exception.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016666

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Missing change of circumstance for loan increase.

Reviewer Comment (2019-09-06): Tolerance exceptions are addressed. Exception Cleared.

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016666

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXX exceeds tolerance of $9,141.00.  Insufficient or no cure was provided to the borrower.

Missing change of circumstance for loan increase.

Reviewer Comment (2019-09-06): AMC received XX25 COC. Exception Cleared. Buyer Comment (2019-09-05): Please see COC LE - confirm refund due is .19 cents

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016667

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

Hazard Insurance Error: Subject hazard insurance policy coverage amount is missing from evidence of insurance.

Missing all pages of the current Hazard Insurance Certificate for the subject property.

Reviewer Comment (2019-09-06): AMC received a copy of the HOI policy dated 8/8/18-8/8/19 Buyer Comment (2019-09-06): HOI for review

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016667

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Missing all pages of the current Hazard Insurance Policy for the subject property.

Reviewer Comment (2019-09-06): AMC received a copy of the HOI policy dated 8/8/18-8/8/19

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016667

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-05): XXXXXX has elected to waive this exception.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016667

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance Policy expires within 90 days of the Note Date.

Policy is not in effect for a minimum of 60 days after consummation.

Reviewer Comment (2019-09-10): AMC received the revised HOI policy effective on 8/XX19-08XX20. Buyer Comment (2019-09-09): Updated HOI for review

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208016668

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-08-19): Supplement Title report provided

08/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208016668

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Timing Before Closing

TILA-RESPA Integrated Disclosure: Revised Loan Estimate provided on XXXXXX not received by borrower at least four (4) business days prior to closing.

Evidence revised LE received at least 4 business days prior to closing is not provided.

Buyer Comment (2019-08-21): waive Reviewer Comment (2019-08-20): Regraded to EV2-B based on the final LE being received at least 4 days prior to consummation, prior LE received less than 4 days from consummation. Reviewer Comment (2019-08-20): AMC received Disclosure Summary.  Document provided appears to be for the Revised Final LE issued on XXXXXX.  Please provide confirmation of receipt for the XXXXXX LE. Thanks

08/21/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208016668

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Employment history for prior employment to complete 2 full years

Reviewer Comment (2019-09-18): Agree with lender. 1099 for XX and Cert of Cancellation for business provided. Buyer Comment (2019-09-18): uploaded 1099s for XX from XXXXXX and XX from XXXXXX. There is not XX 1099 from XXXXXX because this company was dissolved into XXXXXX. They are owned by the same employer. You can see the addresses on the 1099s are the same Reviewer Comment (2019-08-26): Documentation provided to show that LLC was dissolved XXXXXX. Missing XX and XX W-2for verification of employment to complete the 2-year period. Reviewer Comment (2019-08-23): 2 years verification of employment is required. Please provide dissolution of LLC and 20XXXX W'2 for income verification that borrower was employed over period for complete 2 years income verification. Buyer Comment (2019-08-23): XXXXXX is no longer in business Reviewer Comment (2019-08-19): WVOE provided to show borrower start date as a 1099 employee on XXXX and conversion to W-2 as of XXXXXX. Missing WVOE for the Co-borrower's previous employment with XXXXXX to complete verification of a 24 month work history.

09/18/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208016668

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-19): waive

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208016668

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

Buyer Comment (2019-08-19): waive

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208016668

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Buyer Comment (2019-08-19): waive

08/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208016669

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator disclosure not provided. Unable to determine if compensation was based on a term of the transaction

Buyer Comment (2019-09-10): waive

09/10/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016669

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. CD was blank in this section. Amount required to cure is $188.27 No evidence in file that cure was provided to borrower

Reviewer Comment (2019-09-11): COC - loan program changed

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016669

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-1,495.73  is less than amount of binding Lender Credit previously disclosed in the amount of $-1,684.00.

Lender Credits of $0.00 is less than amount previously disclosed of  $-1684.00.

Reviewer Comment (2019-09-11): COC - loan program changed Buyer Comment (2019-09-10): final CD reflects lender credit of $1495.73 (0.555% origination credit)

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016670

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow owner occupied loan closing in the name of the borrower LLC vs program requirement that ownership must be vested as individual for a primary residence.

Overall reduction of approximately $529.00. LTV is 82.53% < program max of 85% One open mortgage reflects 0X30 for the past 12 months.  No public records. Borrower has been self-employed for the past 35 years as the XXXXXX Credit score is 711, 11 points > program requirement of 700.

Originator Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-30): C;ient has elected to waive this exception based on compensating factors.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208016670

XXXXXX

XXXXXX

Compliance

Compliance

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 Cancel occurs prior to expected date(s).

Reviewer Comment (2019-09-09): Updated RTC provided.

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208016670

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Homeowners insurance premium of $2,873.82 does not match the actual amount of $2,036.64

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208016670

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Closing Costs Financed

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.

Disclosure does not reflect an amount for Closing Costs Financed, but this should be $43,474.58

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208016670

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208016670

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Re-Inspection Fee.  Fee Amount of $175.00 exceeds tolerance of $150.00.  Sufficient or excess cure was provided to the borrower at Closing.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208016670

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Reviewer Comment (2019-09-11): Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form. Buyer Comment (2019-09-10): See trailing documents showing delivery and explanation Reviewer Comment (2019-09-09): Provide the following: Letter of Explanation, Proof of Delivery

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208016671

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Borrower Ability to Repay Attestation not provided

Borrower Ability to Repay not provided

Reviewer Comment (2019-09-09): ATR provided

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Date appraisal provided was before final valuation was validated. Unable to determine the compliance timing requirement

Buyer Comment (2019-09-03): XXXXXX has elected to waive Reviewer Comment (2019-09-03): Appraisal receipt email dated XXXXXX, however effective date of appraisal is XXXXXX.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Borrower not provided with Right to receive a copy of the Appraisal disclosure

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.78060% or Final Disclosure APR of 6.81000% is in excess of allowable threshold of APOR 3.86% + 1.5%, or 5.36000%.  Non-Compliant Higher Priced Mortgage Loan.

Final Disclosure APR of 6.8100% exceeds the APOR threshold of 5.3600%

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Borrower not provided with Right to receive a copy of the Appraisal disclosure

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

List of Homeownership Counseling Organization not in file.

Reviewer Comment (2019-08-30): Initial disclosure provided.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Your Home Loan Toolkit disclosure was not in file.

Reviewer Comment (2019-08-30): Initial disclosure provided.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure was not provided to the borrower at least 3 business days before closing

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $13,299.50 may be required.

Loan Estimate was not provided.The Closing Disclosure was uses to estimate a baseline for tolerance testing A fee tolerance cure of $13,299.50 may be required

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Servicing Disclosure not provided to the borrower

Reviewer Comment (2019-08-30): SitusAMC received required documents, exception is cleared.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

File contains evidence of delivery prior to report date.

Buyer Comment (2019-09-03): XXXXXX has elected to waive Reviewer Comment (2019-09-03): Appraisal receipt email dated XXXXXX, however effective date of appraisal is XXXXXX.

09/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow the use of business funds without a CPA letter vs program requirement to obtain a statement from a CPA stating that the withdrawal of funds will not have a negative impact on the business

Credit history reflects paid as agreed since child support 30 day late in XXXXXX. VOR reflects paid as agreed for past 13 months. No public records. Borrower has been self-employed for the past 9 years as XXXXXX 26.90584% DTI on this Alt documentation loan < 43% guideline max - 16.09416% below program guideline maximum 761 representative FICO score > 680  guideline minimum - 71 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-26): Client has elected to waive this exception based on compensating factors.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

No changed circumstance was located in the loan file that would explain the increase.  Cure required. Unable to address the exception.

Reviewer Comment (2019-09-03): Tolerance exceptions are addressed. Exception Cleared.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016671

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXX exceeds tolerance of $3,655.00.  Insufficient or no cure was provided to the borrower.

No changed circumstance was located in the loan file that would explain the increase.  Cure required. Unable to address the exception.

Reviewer Comment (2019-09-03): AMC received XX05 COC. Exception Cleared. Buyer Comment (2019-09-03): Transfer Tax amount depend of the loan amount. The Loan on the revised LE dated 4.5.XX increased from $275,200.00 (Initial LE) to $xxxx. See attached Initial CD and Revised Initial CD and COC. According the above, no tolerance cure need.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - HPML Status

HPML - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Borrower not provided with right to receive copy of appraisal disclosure

Reviewer Comment (2019-09-12): SitusAMC received required documents, exception is cleared.

09/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Servicing Disclosure Status

File does not evidence the consumer was provided with the Servicing Disclosure.

Servicing Disclosure not provided to the borrower

Reviewer Comment (2019-09-12): SitusAMC received required documents, exception is cleared.

09/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA Disclosure - List of Homeownership Counseling Organizations Missing

RESPA Disclosure Rule (Dodd-Frank 2014): Creditor did not provide List of Homeownership Counseling Organizations to borrower.

List of Homeownership Counseling Organization not provided to the borrower

Reviewer Comment (2019-09-11): Counseling Disclosure and list provided

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Home Loan Toolkit disclosure not provided to the borrower

Reviewer Comment (2019-09-12): SitusAMC received required documents, exception is cleared.

09/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA-RESPA Integrated Disclosure: application date on or after 10/3/2015, no Loan Estimates in the Loan File

TILA-RESPA Integrated Disclosure: Loan Estimate not provided within loan images to evidence delivery to the Borrower(s).  The earliest Closing Disclosure provided in the loan file was used as the estimated baseline for Tolerance Testing.  Depending on the actual values on the initial Loan Estimate, a fee tolerance cure of up to $7,346.43 may be required.

Loan Estimate not provided. The Closing Disclosure was used as the estimated baseline for tolerance testing

Reviewer Comment (2019-09-12): SitusAMC received required documents, exception is cleared.

09/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Appraisal Disclosure - ECOA Status

ECOA - File does not evidence the consumer was provided with the right to receive a copy of the Appraisal Disclosure.

Borrower not provided with right to receive a copy of the appraisal disclosure

Reviewer Comment (2019-09-11): Right to receive copy of appraisal disclosure provided

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Good faith redisclosure

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 8.11620% or Final Disclosure APR of 8.12600% is in excess of allowable threshold of APOR 3.65% + 1.5%, or 5.15000%.  Non-Compliant Higher Priced Mortgage Loan.

Final Closing Disclosure APR of  8.12600% exceeds the allowable APOR threshold of 5.1500%

Reviewer Comment (2019-09-11): Appraisal provided to the borrower on XXXXXX

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016672

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing verification of ownership % for XXXXXX

Reviewer Comment (2019-09-17): Agree with lender. Buyer Comment (2019-09-16): The borrower has two businesses.  The one that is being used for income is XXXXXX.  I obtained an updated CPA letter with start date and business name for this one.  The business they are questioning is XXXXXX.  This was only in the file for assets/reserves.  I believe we already have what we need for that business verification, however those funds are actually no longer needed so I have pulled out the funds, statements, and business documentation as this will make it easier. Reviewer Comment (2019-09-11): CPA letter provided confirms self-employment and ownership percentage, but does not state the name of the business and the start date. Letter is also missing the CPA's license number.

09/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

No cure provided

Reviewer Comment (2019-09-16): COC - rate lock

09/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

208016672

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $2,938.37 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

No cure provided

Reviewer Comment (2019-09-16): COC - rate lock

09/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

A

C

A

C

A

A

A

Non QM

Non QM

Yes

208016673

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Closing Costs Financed

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed Closing Costs Financed that does not match actual amount of closing costs financed.

Final CD reflects $0 in financed charges on page 3 yet amount financed per documentation is $12,057.58.

Buyer Comment (2019-09-06): XXXXXX has elected to waive

09/06/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

208016673

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Revised LE dated XXXX19 was acknowledged as being received by the borrower on XXXX19 the same date as the initial CD.

Buyer Comment (2019-09-06): XXXXXX has elected to waive

09/06/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

No Defined Cure

B

B

B

B

B

B

A

A

Non QM

Non QM

No

208016673

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

PITI for borrower's investment property excluded from DTI as the debt is paid by the borrower's father who also rents the property.  DTI with PITI included is 54.939%.  Approved Lender Exception in file.

No public records Borrower has been employed in the same line of business for the past 20 years. DTI is 34.44955%, 15.55045% < program maximum of 50%. Reserves are 72 months, 68 months > program requirement of 4 months. Credit score is 701, 61 points > program requirement of 640.  No public records.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-06): Client has elected to waive this exception based on compensating factors.

09/06/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Rate/Term

B

B

B

B

B

B

A

A

Non QM

Non QM

No

208016674

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016674

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure No Seller Paid Fees Primary Residence First Lien

TRID Final Closing Disclosure XXXXXX on a first lien purchase transaction did not disclose any Seller paid fees/charges on page 2. (Points and Fees testing limited to Borrower paid fees.)

Seller CD not provided

Reviewer Comment (2019-08-30): Seller CD provided. Buyer Comment (2019-08-30): Please see PCCD, LOE, LABEL

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016674

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Fees seller paid fees do not match Consumer's Final CD

TILA-RESPA Integrated Disclosure: the Seller's final CD total seller paid fee amounts do not match the values used for compliance testing.

Final CD did not reflect any Seller paid costs.  PCCD completed with the Seller paid fees on XXXX19.

Reviewer Comment (2019-08-30): Letter of Explanation & Corrected Closing Disclosure provided.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016674

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD.

PCCD and LOE provided.

Reviewer Comment (2019-08-30): Letter of Explanation & Corrected Closing Disclosure provided.

08/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-09-06): waive

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA Dodd-Frank - Mandatory Arbitration

Truth in Lending Act (Dodd-Frank 2013): Loan documents include terms that require arbitration or any other non-judicial procedure to resolve any dispute or settle any claim arising out of the loan transaction.

Reviewer Comment (2019-09-09): Reviewed Note and mortgage. Loan documents do not require arbitration. Condition cleared. Buyer Comment (2019-09-06): Please advise what is needed to clear

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-06): waive

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

"Exceeds legal limit by" is less than the amount of the required cure. CD indicates cure of $44.95 in this section.  Amount to cure is $131.40 less cure of $44.95. Remaining cure is $86.45. No evidence in file that cure was provided to Borrower

Reviewer Comment (2019-09-13): Tolerance exceptions are addressed. Exception Cleared.

09/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $854.00 exceeds tolerance of $736.00 plus 10% or $809.60.  Insufficient or no cure was provided to the borrower.

Ten Percent Fee Tolerance exceeded. Total amount of $854.00 exceeds tolerance of $736.00 plus 10% or $809.60.  Insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-09-09): cure provided at closing for 10% tolerance exception Buyer Comment (2019-09-06): cure applied on final cd

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $21,125.00 exceeds tolerance of $21,038.00.  Insufficient or no cure was provided to the borrower.

Discount fees increased from $21,038.00  to  $21,125.00 without a valid change circumstance. Tolerance exceeded. No evidence cure provided to borrower.

Reviewer Comment (2019-09-13): AMC received XX16 COC. Exception Cleared. Reviewer Comment (2019-09-12): AMC received XX24 COC however the fee increased on the XX16 CD. Please provide corrected CD, LOE, and refund check to cure. Buyer Comment (2019-09-11): Uploaded 8/16 COC again. COC reflects interest Rate lock at 6.735% with 1.625% Discount Points. Reviewer Comment (2019-09-10): The 8/16 COC provided only states there was a tolerance cure and does not provide any additional information.  Please provide additional details for on COC Buyer Comment (2019-09-09): COC dated 8/16 was uploaded that reflects loan re-lock with 1.625% Discount Points Reviewer Comment (2019-09-09): Points increased on the XXXXXX to $21,125 and the file does not contain a valid COC for the 8/XXXX CD.  COC was provided for XXXXXX advising the loan was re-locked but the fee increased on the XXXXXX CD.

09/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208016675

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Purchase Agreement / Sales Contract not provided

Addendum to purchase contract lowering price to $xxxxx

Reviewer Comment (2019-09-06): AMC received the signed sales contract addendum with price as xxxxx.

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure XXXXXX 12:00:00 AM was received

Buyer Comment (2019-09-06): waive

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure XXXXXX 12:00:00 AM was received.

Buyer Comment (2019-09-06): waive

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.   Property Tax annual amount of $22,125.35 as indicated on the Tax Cert prepared by Closing Agent does not match CD

Reviewer Comment (2019-09-09): Tax cert in file has combined taxes of $13878.59 (document 336) Buyer Comment (2019-09-06): CD reflects payment of $10,497.37 which matches the note

09/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208016675

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception: Allow funds for down payment and closing costs coming from borrowers business accounts vs program requirement that if funds in a business bank or brokerage account have not been transferred to the borrowers person accounts, such funds may not be included in down payment and closing funds.

No public records, one closed mortgage reflects paid as agreed DTI is 20.35272%, 29.64728% < program maximum of 50% Reserves are 110% of the loan amount + 207 months ($3,709.360 total reserves), 200 months > program requirement of reserves of 110% of the loan amount + 7 months (6 months + 1 additional month for additional investment property owned)

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-05): Client has elected to waive this exception based on compensating factors.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016675

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Guideline Requirement: Representative FICO score discrepancy.

Representative FICO score of ___ is less than Guideline representative FICO score of ___.

No public records, one closed mortgage reflects paid as agreed DTI is 20.35272%, 29.64728% < program maximum of 50% Reserves are 110% of the loan amount + 207 months ($3,709.360 total reserves), 200 months > program requirement of reserves of 110% of the loan amount + 7 months (6 months + 1 additional month for additional investment property owned)

Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-05): Client has elected to waive this exception based on compensating factors.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208016675

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $854.00 exceeds tolerance of $736.00 plus 10% or $809.60.  Sufficient or excess cure was provided to the borrower at Closing.

09/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided an incorrect amount that the Total Closing Costs exceeded the legal limits

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $-4,228.95  is less than amount of binding Lender Credit previously disclosed in the amount of $-5,000.00.

Final Lender Credit of $4,228.95 is less than amount Lender previously stated of $-5,000.00

Reviewer Comment (2019-09-03): COC - rate lock Buyer Comment (2019-08-30): Change of circumstance for change on loan amount uploaded.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Reinspection Fee.  Fee Amount of $200.00 exceeds tolerance of $150.00.  Insufficient or no cure was provided to the borrower.

Reinspection Fee Amount of $200.00 exceeds tolerance of $150.00. $50.00 cure provided on the final CD however not allocated as of yet due to additional tolerance exception open requiring a cure.

Reviewer Comment (2019-09-03): $50.00 cure provided at closing. Buyer Comment (2019-08-30): COC uploaded for other tolerance.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation disclosure not provided . Unable to determine if compensation was based on a term of the transaction

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail.

DTI exceeds program maximum of 43%. Lender Exception in file for DTI at 46.549% please provide a revised exception.

Reviewer Comment (2019-09-03): Corrected REO section of Clarity, removing departing residence.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Wages

Ability to Repay (Dodd-Frank 2014): Unable to verify Wages/W-2 income using reasonably reliable third-party records.

Missing paystubs.

Reviewer Comment (2019-09-03): Pays tubs provided. Buyer Comment (2019-08-30): Pay stubs uploaded

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 46.80883% moderately exceeds the guideline maximum of 43.00%. (DTI Exception is eligible to be regraded with compensating factors.)

DTI of 46.80883% exceeds Lenders Guidelines fo 43%. Lender Exception in file for DTI at 46.549% please provide a revised exception.

Credit score is 756, 96 points > program requirement of 660; Reserves are 5.16 months, 2.16 months > program requirement of 3 months; One Open mortgage reflects 0x30 since inception 10/2006; One closed mortgage reflects paid as agreed; Perfect credit history since inception of earliest account opened 12/2000; Subject is a new construction; No Public Records. Guideline variance approved by lender at time of origination. One closed mortgage reflects paid as agreed. Perfect credit history since inception of earliest account opened XXXXXX. No public records Guideline variance approved by lender at time of origination. One open mortgage reflects 0x30 since inception XXXXXX Guideline variance approved by lender at time of origination. Credit score is 756, 96 points > program requirement of 660

Aggregator Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-06): Client elects to waive the exception with verified compensating factors Buyer Comment (2019-09-05): Revised exception uploaded.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

DTI exceeds program maximum of 43%. Lender acknowledged exception in file.

Reviewer Comment (2019-09-03): Corrected REO section of Clarity, removing departing residence.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Transfer of appraisal to Lender is in file

Buyer Comment (2019-09-05): XXXXXX has elected to waive this exception.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Lender acknowledged exception in file for DTI > 43%. Lender Exception in file for DTI at 46.549% please provide a revised exception.

Credit score is 756, 96 points > program requirement of 660; Reserves are 5.16 months, 2.16 months > program requirement of 3 months; One Open mortgage reflects 0x30 since inception 10/2006; One closed mortgage reflects paid as agreed; Perfect credit history since inception of earliest account opened 12/2000; Subject is a new construction; No Public Records. Guideline variance approved by lender at time of origination. One closed mortgage reflects paid as agreed. Perfect credit history since inception of earliest account opened XXXXXX. No public records Guideline variance approved by lender at time of origination. One open mortgage reflects 0x30 since inception XXXXXX Guideline variance approved by lender at time of origination. Credit score is 756, 96 points > program requirement of 660

Aggregator Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-06): Client elects to waive the exception with verified compensating factors Buyer Comment (2019-09-05): Revised exception uploaded.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Reserves of 1.32 is less than program requirement of 3 months PITIA

Reviewer Comment (2019-09-03): Settlement statement from prior home provided. Buyer Comment (2019-08-30): Settlement statement from prior home uploaded

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Missing pay stubs and DTI exception.

Reviewer Comment (2019-09-06): Client elects to waive the exception with verified compensating factors Buyer Comment (2019-09-05): Revised exception uploaded. Reviewer Comment (2019-09-03): Lender Exception in file for DTI at 46.549% vs 46.808% actual, please provide a revised exception. Buyer Comment (2019-08-30): Pay stubs uploaded

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Loan Package Documentation

Closing / Title

Missing Final HUD-1

Missing final HUD-1 on sale of prior primary residence located at XXXXXX (Note: payment not included in DTI; must show proof mortgage paid in full)

Reviewer Comment (2019-09-03): Final HUD-1 provided. Buyer Comment (2019-08-30): Settlement statement from prior home uploaded

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Credit

Missing Document

General

Missing Document: Stated not provided

Missing Lexis Nexis as indicated on loan approval showing prior mortgage paid in full

Reviewer Comment (2019-09-03): Lexis Nexis provided. Buyer Comment (2019-08-30): Lexis Nexis uploaded

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Missing evidence of Net Proceeds from sale of prior residence.

Reviewer Comment (2019-09-03): Settlement statement from prior home provided.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Program requirement

Reviewer Comment (2019-09-03): Pay stubs provided. Buyer Comment (2019-08-30): Pay stubs uploaded

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-08-30): XXXXXX has elected to waive this exception.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision REO Principal and Interest Amount Considered

Ability to Repay (Dodd-Frank 2014): REO has no P&I amount but is not indicated as a free & clear owned property.

Reviewer Comment (2019-09-03): Corrected REO section of Clarity, removing departing residence.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

D

B

C

B

D

B

A

A

Non QM

Non QM

No

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2019-09-06): Client elects to waive the exception with verified compensating factors

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

208016676

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Reinspection Fee.  Fee Amount of $200.00 exceeds tolerance of $150.00.  Sufficient or excess cure was provided to the borrower at Closing.

$50.00 cure provided at closing.

09/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

D

B

C

B

D

B

A

A

Non QM

Non QM

Yes

208016677

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-05): XXXXXX has elected to waive this exception.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208016677

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

Seller closing disclosure missing

Buyer Comment (2019-09-05): XXXXXX has elected to waive this exception.

09/05/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208016678

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Missing a copy of the final title insurance policy. No policy amount reported on the preliminary report in file.

Reviewer Comment (2019-08-15): Final Title Policy provided Buyer Comment (2019-08-14): Updated Title with Loan Amount

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

B

A

Non QM

Non QM

No

208016678

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

Title Policy is Preliminary or Commitment, and not a Final Title Policy.

Missing a copy of the final title insurance policy

Reviewer Comment (2019-08-15): Final Title Policy provided

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

B

A

Non QM

Non QM

No

208016678

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Missing documentation to support the monthly HOA dues for this property. Used the stated $370 monthly for qualifying per 1003.

Reviewer Comment (2019-08-15): HOA Verification provided Buyer Comment (2019-08-14): HOA verification for XXXXXX

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

B

A

Non QM

Non QM

No

208016678

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow -  Monthly Escrow Payment

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX disclosed the Monthly Escrow Payment that does not match the actual escrow payment for the loan.

CD escrow payment 2,137.68 < CD first projected escrow payment 2,137.69

Reviewer Comment (2019-09-06): Escrows were correctly reflected on the final CD. Buyer Comment (2019-09-05): The escrows are identical Ins $127.27 an Taxes $2010.41 = $2137.68

09/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

B

A

Non QM

Non QM

Yes

208016678

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Date received XXXX19 > closing date XXXX19.

Buyer Comment (2019-08-16): XXXXXX has elected to waive this exception

08/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

A

C

B

B

A

Non QM

Non QM

No

208016678

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Missing transfer letter from XXXXXX

Reviewer Comment (2019-08-15): Appraisal assignment letter provided Buyer Comment (2019-08-14): HOA verification for XXXXXX, Transfer letter

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

B

A

Non QM

Non QM

No

208016678

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Finance charge under disclosed $2,435.00. Unable to determine cause due to missing itemization. Appears to be the Escrow Settlement.

Reviewer Comment (2019-09-18): Letter of Explanation, Proof of Delivery, Refund check for under-disclosed amount of $2435, Corrected CD provided. Buyer Comment (2019-09-17): PCCD, LOX, Refund and UPS label Reviewer Comment (2019-08-30): AMC reviewed XX25 Mavent report. The escrow fee is included in the finance charge. The fee is considered an APR fee. To cure provide a Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, and Corrected CD. Buyer Comment (2019-08-29): Please see 7/25 Mavent  uploaded on 8/16 *See Escrow fee for $2435* Reviewer Comment (2019-08-27): Mavent compliance report in file does not indicate that the Lender included the Settlement fee in the APR calculation.  This is an APR fee.  To cure a Corrected CD, copy of refund check for the underdisclosed amount, letter of explanation and proof of delivery is required. Buyer Comment (2019-08-26): Initial LE disclosed Settlement Fee of $3365 Reviewer Comment (2019-08-23): AMC reviewed the exception. The calculated finance charges are: Admin Fee $1150, Flood Cert $15, Mortgage Broker Fee $13509.93, Processing Fee $795, Tax Service Fee $90, Title-Courier $100, and Title-Settlement $2435. Buyer Comment (2019-08-22): Please be specific on Finance charges. What is missing or what is the shortfall? Buyer Comment (2019-08-22): Please see Lender credit $1045. Reviewer Comment (2019-08-20): Only document uploand on 8/XX19 is a revised Seller's CD issued on 8/XX19 with no closing date and an 8/2/19 funding date.  Exception stands.  To cure provide a Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, and Corrected CD. Buyer Comment (2019-08-19): 8/2 CD Reviewer Comment (2019-08-19): No 8/2 CD located in the loan file.  Escrow fee is a traditional finance charge.  A PCCD, LOE, copy of refund check and re-open rescission is require in order to address the exception. Buyer Comment (2019-08-16): Mavent 7/25 Buyer Comment (2019-08-16): Correct HUD  from 8/2 Reviewer Comment (2019-08-15): Mavent report received and reviewed.  The settlement fee was increased, as well as some of the other fees listed on the Mavent report were not disclosed on the final CD.  A Corrected CD, copy of refund check for the under-disclosed amount, letter of explanation and proof of delivery is required to cure. Buyer Comment (2019-08-14): Mavent report uploaded for review.

09/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

B

C

A

C

B

B

A

Non QM

Non QM

Yes

208016678

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Missing the compliance report as required per guidelines.

Reviewer Comment (2019-08-15): Compliance report provided. Buyer Comment (2019-08-14): Mavent Report uploaded for review.

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

B

A

Non QM

Non QM

No

208016679

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insurance address does not match Note address.

Subject address on the note is XXXXXX Insurance reflects XXXXXX

Reviewer Comment (2019-08-14): Per USPS.com, all versions of a dress are correct. Buyer Comment (2019-08-13): Per XXXXXX has its own policy. I have uploaded.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016679

XXXXXX

XXXXXX

Credit

System

General

Flood Certificate Subject Address does not match Note address.

Subject address on the note is XXXXXX .  Flood determination reflects XXXXXX

Reviewer Comment (2019-08-14): Per USPS.com, all versions of a dress are correct.

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

CD issued on XXXXXX reflects correct escrow payment of $2,836.37. Missing letter of explanation to the borrower disclosing the changes made.

Buyer Comment (2019-08-15): XXXXXX has elected to waive this exception

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

CD issued on XXXXXX reflects correct closing (consummation) date of XXXXXX. Missing letter of explanation to the borrower disclosing the changes made.

Buyer Comment (2019-08-15): XXXXXX has elected to waive this exception

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Property Value

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed an Appraised Property Value that did not match the actual Property Value for the loan.

CD issued on XXXXXX reflects correct appraised value of $765,000. Missing letter of explanation to the borrower disclosing the changes made.

Buyer Comment (2019-08-15): XXXXXX has elected to waive this exception

08/15/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Compliance Engine Required from Mavent or ComplianceEase. For a Loan to be eligible for sale to XXXXXX, the Loan must have passed a compliance engine query that indicates that the loan complies with all applicable federal, state and local laws and regulations.

Reviewer Comment (2019-08-14): Mavent provided. Buyer Comment (2019-08-13): Uploaded For Review-Mavent Report

08/14/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016679

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to use re-certification of value for subject property on a transferred appraisal from another lender to extend the appraisal expiration date vs program requirement that an expired appraisal report must have a full new appraisal performed and revalued.

Perfect credit history with never a late payment with earliest inception date of XXXXXX. No public records. 726 representative FICO score > 700 guideline minimum Reserves are 58.16 > program requirement of 3 months Borrower has self-employed as XXXXXXow for the past 14.58 years and has been in the same line of work for the past 20 years. LTV is 73.20% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-12): Client has elected to waive this exception based on compensating factors.

08/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

The file contained documentation verifying the borrower was provided with a copy of the appraisal on XXXX/XX, which is prior to the appraisal report date of XXXXXX.

Buyer Comment (2019-08-14): XXXXXX has elected to waive this exception

08/14/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1 -  October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate.

Monthly escrow payment is $623.63 or $7,483.56 annual amount. CD issued XXXXXX reflects costs over 1 year of $6,567.44. CD issued XXXXXX reflects $6,859.93.

Reviewer Comment (2019-09-10): AMC received XX29 CD. Exception Cleared. Buyer Comment (2019-09-09): Uploaded For Review: CD Reviewer Comment (2019-09-06): AMC reviewed exception. Please provide the XX29 CD as it is not located in file. Buyer Comment (2019-09-05): These are the dates of the CD's for this loan:  X/XX - initial CD; X/XX - consummation CD; X/XX - CD provided during rescission period (was provided to settlement agent, borrower went to office to sign) Reviewer Comment (2019-08-15): AMC received PCCD correcting escrow payment and RTC however it appears the incorrect CD may be used as the final CD for testing. Please indicate if the CD issued XX01 is the final CD or if the XX24 CD is the final CD. The XX01 CD is indicated as a PCCD as the close date is XXXXXX. If the XX01 is the final CD please provide attestation on the correct issue/close date. Buyer Comment (2019-08-14): Uploaded For Review-PCCD Docs/ROR

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan.

CD issued on XXXXXX reflects correct escrow payment for payment stream 1 of $623.63. Missing letter of explanation to the borrower disclosing the changes made.

Reviewer Comment (2019-09-10): AMC received XX29 CD. Exception Cleared. Buyer Comment (2019-09-09): Uploaded For Review: CD Reviewer Comment (2019-09-06): AMC reviewed exception. Please provide the XX29 CD as it is not located in file. Buyer Comment (2019-09-05): These are the dates of the CD's for this loan:  X/XX - initial CD; X/XX - consummation CD; X/XX - CD provided during rescission period (was provided to settlement agent, borrower went to office to sign) Reviewer Comment (2019-08-15): AMC received PCCD correcting escrow payment and RTC however it appears the incorrect CD may be used as the final CD for testing. Please indicate if the CD issued XX01 is the final CD or if the XX24 CD is the final CD. The XX01 CD is indicated as a PCCD as the close date is XXXXXX. If the XX01 is the final CD please provide attestation on the correct issue/close date. Buyer Comment (2019-08-14): Uploaded For Review-PCCD docs/ROR

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate Initial Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

CD issued on XXXXXX reflects correct estimated monthly payment for payment stream 1 of $4,075.29. Missing letter of explanation to the borrower disclosing the changes made.

Reviewer Comment (2019-09-10): AMC received XX29 CD. Exception Cleared. Buyer Comment (2019-09-09): Uploaded For Review: CD Reviewer Comment (2019-09-06): AMC reviewed exception. Please provide the XX29 CD as it is not located in file. Buyer Comment (2019-09-05): These are the dates of the CD's for this loan:  X/XX - initial CD; X/XX - consummation CD; X/XX - CD provided during rescission period (was provided to settlement agent, borrower went to office to sign) Reviewer Comment (2019-08-15): AMC received PCCD correcting escrow payment and RTC however it appears the incorrect CD may be used as the final CD for testing. Please indicate if the CD issued XX01 is the final CD or if the XX24 CD is the final CD. The XX01 CD is indicated as a PCCD as the close date is XXXXXX. If the XX01 is the final CD please provide attestation on the correct issue/close date. Buyer Comment (2019-08-14): Uploaded For Review-PCCD docs/ROR

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Post Close Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Post Closing Disclosure:  Finance Charge of $XXXXXX disclosed on the Final Closing Disclosure dated XXXXXX is under-disclosed by more than $35 compared to the Financed Charge calculated based on fees disclosed on the Post Closing Disclosure of $XXXXXX provided on XXXXXX, a difference of $XXX.

Reviewer Comment (2019-08-15): Borrower paid charges in Section B and prepaid interest increase on the PCCD.  However, PCCD also adds a Section J cure that exceeds amount of increase.

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Post Close Closing Disclosure Total Of Payments Test Rescindable Transactions

TILA-RESPA Integrated Disclosure - Post Closing Disclosure:  Total of Payments of $XXXXXXX disclosed on the Final Closing Disclosure dated XXXXXX is inaccurate by more than $35 compared to the Total of Payments calculated based on fees disclosed on the Post Closing Disclosure of $XXXXXXX  provided on XXXXXX, a difference of $XXX.

Reviewer Comment (2019-08-15): Borrower paid charges in Section B and prepaid interest increase on the PCCD.  However, PCCD also adds a Section J cure that exceeds amount of increase.

08/15/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

AMC received XX29 CD. The number of months collected for Insurance-Hazard in section F is not indicated. Please provide corrected CD and LOE to cure.

Buyer Comment (2019-09-10): XXXXXX has elected to waive this exception

09/10/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

AMC received XX29 CD. The number of months collected for property tax in section F is not indicated. Please provide corrected CD and LOE to cure.

Buyer Comment (2019-09-10): XXXXXX has elected to waive this exception

09/10/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $138.91 exceeds tolerance of $68.00.  Sufficient or excess cure was provided to the borrower at Closing.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Processing Fee.  Fee Amount of $995.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1 -  October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate.

Reviewer Comment (2019-09-10): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan.

Reviewer Comment (2019-09-10): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016679

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Fixed Rate Initial Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

Reviewer Comment (2019-09-10): AMC reviewed exception. The Final CD escrow amount is consistent with IEADS. Exception Cleared.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208016680

XXXXXX

XXXXXX

Credit

Credit

Credit Documentation

Aged document: Credit Report  is more than 90 days prior to the note date.

-

Reviewer Comment (2019-09-20): Credit report dated XXXXXX provided. Buyer Comment (2019-09-18): Updated credit report provided

09/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016680

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Reviewer Comment (2019-09-19): AMC received the E-consent dated 7/1/19. Buyer Comment (2019-09-18): Econsent provided

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016680

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $26,511.00 and disclosure timing violations.

File contains evidence that the borrower received electronic disclosures, missing documentation of consent

Reviewer Comment (2019-09-19): AMC received the E-consent dated 7/1/19. Buyer Comment (2019-09-18): Econsent provided

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016680

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Reviewer Comment (2019-09-19): AMC received the conditional approval with $12,500 in income and a 24.866% DTI. Buyer Comment (2019-09-18): Approval provided

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

A

C

A

C

A

A

A

Non QM

Non QM

No

208016681

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Approval not provided

Reviewer Comment (2019-09-19): AMC received the conditional loan approval for $19,549.15 in income date a 22.171 DTI. Buyer Comment (2019-09-18): Approval uploaded for review.

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208016681

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Home Loan Toolkit Provided

Truth in Lending Act (2015): Creditor or broker did not provide Your Home Loan Toolkit Disclosure to applicant.

Borrower did not receive a copy of Your Home Loan Toolkit Disclosure

Buyer Comment (2019-09-19): XXXXXX has elected to waive this exception.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208016681

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX Subprime Home Loan Threshold Fixed Compliant

XXXXXX Subprime Loan: APR on subject loan of 7.25780% or Final Disclosure APR of 7.28300% is in excess of allowable threshold of Prime Mortgage Market Rate 3.60000 + 1.75%, or 5.35000%.  Compliant SubPrime Loan.

Buyer Comment (2019-09-19): XXXXXX has elected to waive this exception.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

While considered narrow in its defense, the cure provisions under the NY Subprime law allows lenders, when acting in good faith, to make appropriate restitution to the borrower to satisfy the subprime home loan requirements and remove the loan from subprime status.  Cure may be made through refund if (1) there is bona fide evidence of good faith (i.e, lender has controls and policies in place to avoid making subprime loans); and (2) the borrower has not yet brought any action against lender.  There is no time limit for which such restitution must be made.

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208016681

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Allow use of EMD xxxxx directly from borrowers business account vs program requirement that if funds in a business bank account  such funds may not be included in down payment or closing funds

VOR reflects paid as agreed since inception XXXXXX. No public records Borrower has been self-employed for the past 4 years as XXXXXX, in the same line of business for the past 10 years 22.17093% DTI on this Alt documentation loan < 50% guideline max - 27.82907% below program guideline maximum 686 representative FICO score > 640 guideline minimum - 46 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-18): Client has elected to waive this exception based on compensating factors.

09/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208016681

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception for use ot USCIS issued employment Authorization instead of VISA

VOR reflects paid as agreed since inception XXXXXX. No public records Borrower has been self-employed for the past 4 years as XXXXXX, in the same line of business for the past 10 years 22.17093% DTI on this Alt documentation loan < 50% guideline max - 27.82907% below program guideline maximum 686 representative FICO score > 640 guideline minimum - 46 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-18): Client has elected to waive this exception based on compensating factors.

09/18/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Copy of appraisal provided prior to date valuation was performed. Appraisal signed by appraiser on XXXX19, Copy of appraisal sent to borrower on XXXX19

Buyer Comment (2019-09-19): XXXXXX has elected to waive this exception.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $31,502.50 and disclosure timing violations.

Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $31,502.50 and disclosure timing violations.

Reviewer Comment (2019-09-20): AMC received the e-consent dated 7/6/19. Buyer Comment (2019-09-19): Esign Consent provided

09/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Closing Costs Exceeds Limits Amount

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed a tolerance cure amount that does not match the amount disclosed in the Other Costs table.

Final Closing Disclosure provided on XXXXXX disclosed a tolerance cure amount that does not match the amount disclosed in the Other Costs table.  CD page 1 indicates credit of $3,000.00.  CD page 3 show's no cure.  Cure required was $100.00. Cure provided on page 1 is $3,000.00.  Tolerance overage $2,900.00

Buyer Comment (2019-09-19): XXXXXX has elected to waive this exception.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided an incorrect amount that the Total Closing Costs exceeded the legal limit  Final CD page 3 is blank in this section.  Amount of cure is $100.00.  Lump sum cure provided on page 1 of CD is $3,000.  Required cure of $100 - cure credit of $3,000 results in Cure overage is $2,900.00

Buyer Comment (2019-09-19): XXXXXX has elected to waive this exception.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Loan Estimate not delivered to borrower within 3 business days of application. Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations

Reviewer Comment (2019-09-20): AMC received the e-consent dated 7/6/19. Buyer Comment (2019-09-19): Econsent provided

09/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Processing Fee.  Fee Amount of $100.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Title Processing Fee increased by  $100.00 without a valid change circumstance.  Tolerance exceeded. Excessive credit of $3,000 provided to Borrower at close.

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Electronic Storage Fee.  Fee Amount of $25.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Electronic Storage Fee increased by $25.00.  Tolerance exceeded.  Lump sum Credit of $3,000.00 provided to Borrower at closed. (page 1 of final CD)

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Endorsement Fee.  Fee Amount of $1,513.76 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Title - Endorsement Fee increased by $1,513.76 without a valid change circumstance.  Tolerance exceeded.  Lump sum credit of $3,000.00 given to borrower at close. See page 1 of final CD

09/19/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016682

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2019-09-23): AMC received the disclosure tracking with ARM disclosure provided on 7/8/XX. Buyer Comment (2019-09-23): Disclosure tracking provided shows initial ARM disclosure electronically sent to borrower on XXXXXX - please clear. Reviewer Comment (2019-09-23): Application date is XXXXXX per initial application signature of Lender. Compliance report shows the application date is XXXXXX.  ARM disclosure signed XXXXXX. File does not contains any evidence of earlier receipt by the borrower. Buyer Comment (2019-09-20): ARM disclosure provided

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016684

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.  Final CD is blank in this section of page 3.  Amount to cure is $6,599.98.  No evidence of cure provided to borrower.

Buyer Comment (2019-09-17): XXXXXX has elected to waive this exception.

09/17/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208016684

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Discount Points.  Fee Amount of $31,499.98 exceeds tolerance of $26,000.00.  Insufficient or no cure was provided to the borrower.

Loan Discount Points increased from $26,000 to $31,499.98 without a valid change circumstance. Tolerance exceeded. No evidence cure was provided to borrower.

Reviewer Comment (2019-09-19): COC - rate lock Buyer Comment (2019-09-18): See COC / LE provided

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208016684

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Extension Fee.  Fee Amount of $1,125.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Extension Fee increased to $1,125.00  without a valid change circumstance. Tolerance exceeded. No evidence cure was provided to borrower.

Reviewer Comment (2019-09-19): COC - rate lock extension Buyer Comment (2019-09-18): See COC / LE / CD COC provided

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208016684

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $35,620.48 and disclosure timing violations.

Missing esign consent. Disclosures sent electronically may result in a fee tolerance violation of up to $35,620.48 and disclosure timing violations.

Reviewer Comment (2019-09-19): cure provided at closing and COC provided Buyer Comment (2019-09-17): Econsent provided

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208016684

XXXXXX

XXXXXX

Property

Credit

Guideline Issue

Per guidelines, the subject property cannot be greater than 20 acres.

Lender acknowledged exception to allow xxxx acres vs program maximum of 15 acres

Perfect credit history with never a late payment, spanning 10 mortgages, with earliest account, inception date of XXXXXX and no public records. COncurrent loan closing with primary purchase transaction. Subject has XXXXX on and within the immediate area as subject is situated within XXXXXX Borrower has been employed as an XXXXXX for the past 20 years 146 months of reserves, 136 months > program requirement of 9 months Credit score is 814, 194 points > program requirements of 620

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-19): Incorrectly set as appraisal exception and lender exception to guidelines. Reviewer Comment (2019-09-19): incorrectly set to appraisal versus credit exception as exception made to guides Reviewer Comment (2019-09-17): Client has elected to waive this exception based on compensating factors.

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208016684

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

- ___

Mortgage statement in file does not break down the monthly escrow for property tax and insurance

Reviewer Comment (2019-09-19): HOI policy and Mtg statement provided. Buyer Comment (2019-09-19): REO XXXXXX Insurance invoice provided showing paid to date $784.10 + acct bal $1174.90 = $1959 annual premium REO XXXXXX Mtg Stmnt shows escrow balance with ytd withdrawal for Insurance of $808 - monthly escrow collected is $370.72 - difference is for taxes - this property is a condo with an monthly assessment of $583.00 (see stmnt in file)  Please clear Reviewer Comment (2019-09-18): Mortgage statement provided for XXXXXX shows there is not escrow account. Received documentation of property taxes, but missing Hazard insurance. First payment letter dated XXXXXX shows monthly hazard payment of $240.87 Mortgage Statement for  XXXXXX provided shows loan has an escrow account, but does not disclose a breakdown of the funds. Unable to determine if the escrow includes taxes and insurance. Buyer Comment (2019-09-17): XXXXXX REO docs provided (Mtg Stmnt, EOI & Tax Cert) XXXXXX REO Mtg Stmnt shows payment includes escrows

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208016684

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $2,040.00 exceeds tolerance of $650.00.  Insufficient or no cure was provided to the borrower.

Appraisal Fee increased from $650.00 to $2,040 without a valid change circumstance. Tolerance exceeded. No evidence cure provided to borrower.

Reviewer Comment (2019-09-19): $1,565.00 cure provided at closing. Buyer Comment (2019-09-18): Final CD reflects a cure credit of $1565 for Appraisal Fee / CDA Fee over legal limit. Please clear.

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208016684

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $325.00 exceeds tolerance of $175.00.  Insufficient or no cure was provided to the borrower.

Collateral Desktop Analysis increased from $325.00 to $175.00 without a valid change circumstance. Tolerance exceeded. No evidence cure provided to borrower.

Reviewer Comment (2019-09-19): $1,565.00 cure provided at closing. Buyer Comment (2019-09-18): Final CD reflects a cure credit of $1565 for Appraisal Fee / CDA Fee over legal limit. Please clear.

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208016684

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $2,040.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing.

$1,565.00 cure provided at closing.

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208016684

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Collateral Desktop Analysis.  Fee Amount of $325.00 exceeds tolerance of $175.00.  Sufficient or excess cure was provided to the borrower at Closing.

$1,565.00 cure provided at closing.

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Final CD evidences Cure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208016684

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow xx acres vs program maximum of 15 acres

Perfect credit history with never a late payment, spanning 10 mortgages, with earliest account, inception date of XXXXXX and no public records. COncurrent loan closing with primary purchase transaction. Subject has XXXXX on and within the immediate area as subject is situated within XXXXXX Borrower has been employed as an XXXXXX for the past 20 years 146 months of reserves, 136 months > program requirement of 9 months Credit score is 814, 194 points > program requirements of 620

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-19): Client has elected to waive this exception based on compensating factors.

09/19/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208016685

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Loan Estimate Timing Electronically Provided

TILA-RESPA Integrated Disclosure: Loan Estimate not delivered to Borrower(s) within three (3) business days of application. Initial Loan Estimate dated XXXXXX was electronically provided without or prior to borrower's consent to receive electronic disclosures. Failure to comply with the provisions of the E-Sign Act and failure to provide good faith estimate of fees timely may result in additional fee tolerance violations.

Reviewer Comment (2019-09-20): AMC received E consent. Exception Cleared. Buyer Comment (2019-09-19): Econsent provided

09/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016685

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Esign Consent Agreement Status

ESIGN Act - Missing esign consent.  TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes.  Disclosures sent electronically may result in a fee tolerance violation of up to $13,065.20 and disclosure timing violations.

Missing esign consent. TRID disclosures provided electronically will not be used to set or rebaseline fees for tolerance purposes. Disclosures sent electronically may result in a fee tolerance violation of up to $13,065.20 and disclosure timing violations

Reviewer Comment (2019-09-20): AMC received E consent. Exception Cleared. Buyer Comment (2019-09-19): Econsent provided

09/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016685

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Demand Feature

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature.

Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan contains a Demand Feature

Buyer Comment (2019-09-19): XXXXXX has elected to waive this exception.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016685

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.  Final CD is blank in this section of page 3.  Amount to cure is $175.00.   No evidence that cure was provided to borrower.

Buyer Comment (2019-09-19): XXXXXX has elected to waive this exception.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016685

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Final/XXXXXX)

Reviewer Comment (2019-09-24): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-09-20): Initial Closing Disclosure provided

09/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016685

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Settlement Service Provider Status

TILA-RESPA Integrated Disclosure: Borrower not provided with list of service providers.

Borrower not provided with list of service providers.

Reviewer Comment (2019-09-20): AMC received SSPL. Exception Cleared. Buyer Comment (2019-09-19): SSPL provided

09/20/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016685

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Desk Review Fee.  Fee Amount of $175.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Appraisal Desk Review Fee increased $175.00 without a valid change circumstance. Tolerance exceeded. No evidence that cure was provided to Borrower.

Reviewer Comment (2019-09-24): SitusAMC received required documents, exception is cleared. Buyer Comment (2019-09-20): See trailing documents

09/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208016685

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 8/XXXX 12:00:00 AM was received.

Mailbox rule indicates XX27 LE was received on the same day the first CD was issued, XX30.

Buyer Comment (2019-09-24): XXXXXX has elected to waive this exception.

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208016686

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-09-23): XXXXXX has elected to waive this exception.

09/23/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

B

B

B

B

B

B

A

A

N/A

N/A

No

208016686

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Lender approved exception for LTC exceeding 50% for cash out on investment property, minimum credit score of 620

No public records Borrower has been XXXXXX for the past 7 years. Reserves are 17.72 months, 14.72 month > program requirement of 3 months Credit score is 635, 15 points > program requirement of 620. No public records

Originator Pre-Close Originator Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-23): Client has elected to waive this exception based on compensating factors.

09/23/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

B

B

B

B

B

B

A

A

N/A

N/A

No

208016686

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Combined loan to value discrepancy.

Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___.

Lender approved exception for LTC exceeding 50% for cash out on investment property, minimum credit score of 620

No public records Borrower has been XXXXXX for the past 7 years. Reserves are 17.72 months, 14.72 month > program requirement of 3 months Credit score is 635, 15 points > program requirement of 620. No public records

Originator Pre-Close Originator Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-23): Client has elected to waive this exception based on compensating factors.

09/23/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

B

B

B

B

B

B

A

A

N/A

N/A

No

208016687

XXXXXX

XXXXXX

Credit

Credit

Credit Eligibility

Public Record Issue:

-

Lender exception provided allowing tax lien to remain open .

Borrower mortgage history is 0x30 since inception XXXXXX.   Borrower only has 1x30 late payment on a credit card in XXXXXX on entire report and no public records. Borrower has been XXXXXX for the past 2.95 years and has been in the same line of work for the past 10 years. DTI is 36.39508%, 13.60492% < program maximum of 50%. Reserves are 14 months , 11 months > program requirement of 3 months. Credit score is 654, 14 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-24): Client has elected to waive this exception based on compensate factors.

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208016687

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-25): waived

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208016687

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Closing Costs Exceeds Limits Amount

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed a tolerance cure amount that does not match the amount disclosed in the Other Costs table.

Final Closing Disclosure provided on XXXXXX disclosed a tolerance cure amount that does not match the amount disclosed in the Other Costs table. Lender credit of $6,300.00 provided on page 1 of final CD

Buyer Comment (2019-09-25): waived

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208016687

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.  Lender credit of $6,300.00 given on page 1 of final CD but not on page 3.

Buyer Comment (2019-09-25): waived

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208016687

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Lender Credit Tolerance Violation

TILA-RESPA Integrated Disclosure: Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00  is less than amount of binding Lender Credit previously disclosed in the amount of $-6,300.00.

Zero Percent Tolerance exceeded for Lender Credits. Final Lender Credit of $0.00 is less than amount of binding Lender Credit previously disclosed in the amount of $-6,300.00.

Reviewer Comment (2019-09-26): Lender credit disclosed properly. Buyer Comment (2019-09-25): Final CD reflects lender credit of $6300

09/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208016687

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ARM Disclosure Timing Test

TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.

Reviewer Comment (2019-09-25): Loan was originated at time of application as fixed rate per COC 8/XX19 loan program changed to ARM. ARM disclosure was provided within 3 days of loan program change. Buyer Comment (2019-09-25): Loan initially disclosed as 30 YR Fixed. Was switched to ARM on  8/13. Uploaded COC and disclosures

09/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208016687

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

CHARM Booklet Disclosure Timing

TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower within three (3) days of application.

Reviewer Comment (2019-09-25): Loan was originated at time of application as fixed rate per COC 8/XX19 loan program changed to ARM. CHARM disclosure was provided within 3 days of loan program change. Buyer Comment (2019-09-25): Loan initially disclosed as 30 YR Fixed. Was switched to ARM on  8/13. Uploaded COC and disclosures

09/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208016687

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Combined loan to value discrepancy.

Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___.

Lender exception in file

Borrower mortgage history is 0x30 since inception XXXXXX.   Borrower only has 1x30 late payment on a credit card in XXXXXX on entire report and no public records. Borrower has been XXXXXX for the past 2.95 years and has been in the same line of work for the past 10 years. DTI is 36.39508%, 13.60492% < program maximum of 50%. Reserves are 14 months , 11 months > program requirement of 3 months. Credit score is 654, 14 points > program requirement of 640.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-24): Client has elected to waive this exception based on compensate factors.

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208311491

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD disclosed loan does not allow for Assumption, however, Note contains Assumption language.

Reviewer Comment (2019-08-26): Waive per client request.

08/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

208311491

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Hazard insurance amount of xxxx (including extended coverage of $65,380.00) is not enough to cover the loan amount of XXXXXX and the estimated replacement cost was not provided on the appraisal. File is missing the insurance company replacement cost estimator to verify that the amount of coverage is sufficient.

Reviewer Comment (2019-10-09): Received the insurance company replacement cost estimator. Buyer Comment (2019-10-08): please see replacement cost estimator Reviewer Comment (2019-09-27): This exception cannot be waived. An insurance replacement cost estimator or updated insurance policy with sufficient coverage to cover the loan amount is required to clear this exception. Buyer Comment (2019-09-18): please see exception

10/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208311491

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Borrowers were qualified without the PITIA for the departure residence and file contains the required MLS listing. However, verified reserves after closing of 6.38 months are insufficient to cover the additional 6 months of reserves that are required for this property.

Borrower has job stability for 24.92 years as XXXXXX Borrowers have residual income of $9,588.01 37.36% DTI on this Bank Statement documentation loan < 50.00% guideline max - 12.64% below program guideline maximum

Originator Originator Originator

Reviewer Comment (2019-09-04): Lender approved exception to waive the required 6 months for the borrowers departure that was listed but not sold at the time of the subject loan's closing.

09/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208311494

XXXXXX

XXXXXX

Credit

Credit

Credit Calculation / Analysis

Missing Document: Alternative Credit Documentation not provided

File contains an e-mail from the Broker that states an internet fee, electricity and test message fee are included as part of the phone bill however, 24 month verification of the phone bill was not provided. In addition, file contains a 12-month bank statement printout that was translated from XXXXXX to US dollars however, the printout does not verify account ownership and any payments reflected on this printout cannot be verified as belonging to the borrower.

33.44% DTI on this Full documentation loan < 50.00% guideline max - 16.56% below program guideline maximum Borrower has residual income of $7,486.09

Originator Originator

Reviewer Comment (2019-09-27): No credit references were provided for the foreign national borrower. Lender approved exception to waive the foreign national alternative credit documentation as required by XXXXXX foreign national guidelines. Buyer Comment (2019-09-27): please see exception Reviewer Comment (2019-09-27): Received a lender exception to waive the foreign national credit report requirement. However, the guidelines require 3 credit reference letters translated to English to verify a 24-month history for each account, if a foreign national credit report is not obtained. If XXXXXX is also waiving the 3 credit reference letters, then the exception must state that. Exception remains. Buyer Comment (2019-09-18): please see exception

09/27/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208311494

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Consumer(s) Final CD disclosed Closing Date XXXXXX, however consummation took place on XXXXXX as indicated by wet signature(s).

Reviewer Comment (2019-09-04): Waive per client request.

09/04/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208311494

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

FACTA Disclosure Missing

FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.

Not applicable.

Reviewer Comment (2019-09-05): Waive per client request.

09/05/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208311494

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Purchase Agreement / Sales Contract not provided

Purchase Agreement and all contract addendums provided in the file were not signed and dated by the borrower and the seller.

Reviewer Comment (2019-10-08): Received Buyer Comment (2019-09-27): please see signed contracts Reviewer Comment (2019-09-27): Received a duplicate purXXXXXX agreement and addendums, none of which have been signed by the borrower and seller. Exception remains until the signed purXXXXXX agreement is provided.

10/08/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208311494

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Non-Assumability Rider to the Note was not provided at the time of audit review.

Reviewer Comment (2019-09-04): Waive per client request.

09/04/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208311494

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - No Income Provided

Ability to Repay (Dodd-Frank 2014): No income or assets converted to a monthly amount was provided to demonstrate ability to repay.

File contains an Employer Letter which reflects the Foreign National borrower's wages in XXXXXX . Because the income was not translated into U.S. dollars as required by XXXXXX Foreign National guidelines, it has been excluded and the loan cannot be tested for the borrower's ability to repay. Upon receipt of the translated income letter, additional conditions may apply.

Reviewer Comment (2019-09-27): Received a currency converter to verify 80,000 XXXX monthly salary = $11,247.60 in XXX dollars.

09/27/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208311494

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail.

Due to Foreign National borrower's income was not translated into U.S.dollars, the subject loan designation is ATR Fail.

Reviewer Comment (2019-09-27): Received a currency converter to verify XXXX monthly salary = $11,247.60 in US dollars. Buyer Comment (2019-09-10): Please see response under "General Ability to Repay" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

Lender to provide updated ATR/QM status

D

B

D

B

C

B

A

A

Non QM

Non QM

Yes

208311494

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Due to Foreign National borrower's income was not translated into U.S.dollars, the subject loan designation is ATR Fail.

Reviewer Comment (2019-09-27): Received a currency converter to verify XXXX monthly salary = $11,247.60 in US dollars.

09/27/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208311494

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

File contains an Employer Letter which reflects the Foreign National borrower's wages in XXXXXX . Because the income was not translated into U.S. dollars as required by XXXXXX Foreign National guidelines, it has been excluded and the DTI cannot be calculated. Upon receipt of the translated income letter, additional conditions may apply.

Reviewer Comment (2019-09-27): Received a currency converter to verify XXXX monthly salary = $11,247.60 in US dollars. DTI is now 33.44%. Buyer Comment (2019-09-10): Please see response under "General Ability to Repay" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208311494

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to Foreign National borrower's income was not translated into U.S.dollars, the subject loan is at ATR Risk.

Reviewer Comment (2019-09-27): Received a currency converter to verify XXXX monthly salary = $11,247.60 in US dollars. DTI is now 33.44%. Buyer Comment (2019-09-10): Please see response under "General Ability to Repay" tab.

09/27/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

D

B

D

B

C

B

A

A

Non QM

Non QM

No

208311495

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Missing Non-Assumability Rider

Reviewer Comment (2019-09-06): Waive per client request.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311495

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

The number of months of prepaid insurance disclosed in section F of the final CD is 2 at $119.00.  Closing Disclosure should reflect 2 months at $94.50.  Provide a post-close CD correcting the number of months and/or monthly amount and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311495

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Final Initial Closing Disclosure dated XXXXXX was not provided to the borrower at least 3 business days prior to the closing date of XXXXXX. File is missing a written and signed statement from the borrower that waives the required waiting period.

Reviewer Comment (2019-09-23): New exception populated. Reviewer Comment (2019-09-23): AMC received XX12 CD however it is signed XXXX19. Exception Stands. Buyer Comment (2019-09-20): Please see attached.  Initial CD was issued 6/XX19 Reviewer Comment (2019-09-19): AMC reviewed exception. The initial CD is required to be received 3 business days from consummation date (XX15). Exception stands. Buyer Comment (2019-09-18): please see final ss. Loan funded on 6/XX19

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208311495

XXXXXX

XXXXXX

Compliance

Compliance

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 Cancel occurs prior to expected date(s).

Right to Cancel was executed by the borrower on XXXXXX with expiration of rescission period ending on XXXXXX however, the Right to Cancel Expected Expiration Date is XXXXXX. Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form is required to cure this exception.

Reviewer Comment (2019-10-10): Received cure docs required Buyer Comment (2019-10-07): please see rtc , delivery, response Reviewer Comment (2019-10-02): Received settlement statement with the final disbursement date however, exception remains. Exception has been reviewed by our compliance department with this response: The exception is caused by the expiration date printed on the Notice of Right to Cancel as XXXXXX when the actual expiration date is XXXXXX. Letter of Explanation to the borrower, Proof of Delivery, and Re-open Rescission using the correct model form are required to cure this exception. Reviewer Comment (2019-09-27): This exception has been sent to our compliance department for review. Buyer Comment (2019-09-18): please see final ss uploaded.  loan did not fund until 6/20

10/10/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311495

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Waiver Less than 3 Days From Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Borrower provided appraisal waiver less than three (3) business days prior to consummation.

Doc was signed XXXXXX and loan closed XXXXXX

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208311495

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

AMC received XX12 CD however it is signed XXXX19. Exception Stands.

Reviewer Comment (2019-09-25): Initial wet signed cd provided Buyer Comment (2019-09-24): please see attached.  borrower acknowledged X/XX cd via email and signed, but dated incorrectly.  attached is the borrowers  email to us acknowledging and the CD on 6/XXXX

09/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Home Improvement

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208311496

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Per XXXXXX income worksheet, borrower was qualified with business bank statement income of $82,159.96 based on 24-month average of the P&L statement for XXXXXX  however, the income stated on the signed Initial 1003 is $40,000.00. XXXXXX Bank Statement guidelines require bank statements for the same time period as the P&L, which in this case is XXXXXX through XXXXXX however, the file only contains 2 bank statements for this company dated XXXXXX and XXXXXX. Because the business bank statement income was not verified in accordance with the  guidelines, the income has been excluded and a DTI cannot be calculated. Upon receipt of the missing 24 months of bank statements, additional conditions may apply.

Amount of residual income: $18,173 FICO score above minimum by 20 points or greater. FICO: 725 PITIA reserves above minimum by 6 months or greater. Number of PITIA Reserves: 387.18

Originator Originator Originator

Reviewer Comment (2019-10-10): Waived with comp factors Reviewer Comment (2019-09-30): Received the full 24 months of bank statements. Borrower was qualified with 24-month average of $82,159.96  calculated from the P&L statement however, the income stated on the signed Initial 1003 is $40,000.00. Using the signed initial 1003 income as required by the guidelines results in a DTI of 54.66%. A lender approved exception with verified compensating factors related to the borrower's ability to repay to A) allow the DTI of 54.66% or B) allow the P&L statement average in lieu of required lower Initial 1003 income is required to wave this exception.

10/10/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

B

A

A

A

A

N/A

N/A

No

208311497

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Loan File

Missing Document: Hazard Insurance Policy not provided

File is missing the Hazard Insurance Policy for the subject property. File only contains insurance policies for the borrower's retained departure residence. Upon receipt of the missing insurance policy for the subject, additional conditions may apply.

Reviewer Comment (2019-10-10): Received Buyer Comment (2019-10-07): please see hoi and replacement cost estimator Reviewer Comment (2019-10-04): As of XXXXXX, still have not received the insurance policy for the subject property.

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Final CD reflects loan is non-assumable however non-assumability rider was not provided.

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311497

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

XXXXXX was verified with only 1 brokerage statement dated XXXXXX. XXXXXX guidelines require the most recent 2 months of statements. Subject loan closed XXXXXX and upon receipt of the missing May XX brokerage statement, additional conditions may apply.

Borrower has residual income of $10,351.84 33.97 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow xxxx account #xxx to be verified with 1 statement when the guidelines require 2 months of statements.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

BBVA checking account #6425 was verified with only 1 bank statement dated XXXXXX. XXXXXX guidelines require the most recent 2 months of statements.

Reviewer Comment (2019-10-04): Received the xxxx April XX statement.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

3 day appraisal waiver provided however proof that appraisal was delivered to borrower prior to closing was not provided (email printout is not dated).

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Invalid Section A Combinations

TILA-RESPA Integrated Disclosure - Loan Costs: Final Closing Disclosure provided on XXXXXX reflects a Paid To party other than to lender or broker for fee within Origination Charges.

Closing Instructions reflects processing fee listed in Section A of CD paid to third party.

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Good Faith Redisclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311497

XXXXXX

XXXXXX

Credit

System

General

Valuation address does not match Note address.

-

Appraisal and Desk Review reflect the subject city as XXXXXX. Flood Cert reflects the city as XXXXXXf. Note, Deed of Trust and all Riders, Tax Record Sheet, Final 1003 and Final Closing Disclosure reflect the city as XXXXXX. File is missing a Zip Code search to verify the subject zip code encompasses these 3 cities.

Reviewer Comment (2019-10-10): Received Buyer Comment (2019-10-07): zip code look up attached Reviewer Comment (2019-10-04): As of XXXXXX, still have not received the zip code search to verify the subject zip code encompasses the cities of XXXXXX. The zip code search provided in the file only verifies XXXXXX

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower was qualified with monthly IRA Distributions of $19,000.00, verified with a letter from a registered representative that states the firm's client is the borrower's daughter who has 2 Inherited IRA accounts, and that the borrower has full access and "can" withdraw $19,000.00 per month. File also contains a letter from the borrower which states that the borrower is 100% controller of the inherited IRA's until the daughter turns 21 years of age in 3.5 years. The most recent 2 months of these IRA statements were not provided in the file. Per XXXXXX Full Doc guidelines, IRA distributions are eligible for qualifying, if a copy of the most recent 1099 is obtained and verification that the borrower has sufficient funds in the IRA to continue the income distributions for at least three years. IRA distributions are only eligible for borrowers over 59 ½ years of age. Because the qualifying IRA Distributions do not meet the guideline requirements, this income has been excluded which results in a DTI of 420.89%.

Reviewer Comment (2019-10-04): Lender approved exception to allow the borrower to be qualified with monthly distributions from an inherited IRA when the borrower is not 59 1/2 years old. Account balance verifies 38.62 months continuance.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 420.89052% significantly exceeds the guideline maximum of 55.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Borrower was qualified with monthly IRA Distributions of $19,000.00, verified with a letter from a registered representative that states the firm's client is the borrower's daughter who has 2 Inherited IRA accounts, and that the borrower has full access and "can" withdraw $19,000.00 per month. File also contains a letter from the borrower which states that the borrower is 100% controller of the inherited IRA's until the daughter turns 21 years of age in 3.5 years. The most recent 2 months of these IRA statements were not provided in the file. Per XXXXXX Full Doc guidelines, IRA distributions are eligible for qualifying, if a copy of the most recent 1099 is obtained and verification that the borrower has sufficient funds in the IRA to continue the income distributions for at least three years. IRA distributions are only eligible for borrowers over 59 ½ years of age. Because the qualifying IRA Distributions do not meet the guideline requirements, this income has been excluded which results in a DTI of 420.89%.

Reviewer Comment (2019-10-04): Lender approved exception to allow the borrower to be qualified with monthly distributions from an inherited IRA when the borrower is not 59 1/2 years old. Account balance verifies 38.62 months continuance. Buyer Comment (2019-09-17): For response, please see "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Due to IRA Distribution income not verified in accordance with the guidelines and a DTI of 420.89%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-04): Lender approved exception to allow the borrower to be qualified with monthly distributions from an inherited IRA when the borrower is not 59 1/2 years old. Account balance verifies 38.62 months continuance. Buyer Comment (2019-09-17): For response, please see "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311497

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to IRA Distribution income not verified in accordance with the guidelines and a DTI of 420.89%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-04): Lender approved exception to allow the borrower to be qualified with monthly distributions from an inherited IRA when the borrower is not 59 1/2 years old. Account balance verifies 38.62 months continuance. Buyer Comment (2019-09-17): For response, please see "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrower was qualified with a DTI of 53.89%. Calculated DTI is 52.28%.

Borrower has residual income of $10,351.84 33.97 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow the borrower to be qualified with monthly distributions from an inherited IRA when the borrower is not 59 1/2 years old. Account balance verifies 38.62 months continuance.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311497

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 52.28478% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower was qualified with a DTI of 53.89%. Calculated DTI is 52.28%.

Borrower has residual income of $10,351.84 33.97 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow the borrower to be qualified with monthly distributions from an inherited IRA when the borrower is not 59 1/2 years old. Account balance verifies 38.62 months continuance.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311498

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The closing date on the final CD is XXXX19, and the loan closed on XXXX19.

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311498

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final Closing Disclosure incorrectly said that the loan is unassumable.

Reviewer Comment (2019-09-09): Waive per client request.

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311498

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Final 1003 disclosed the borrower owns a condo in Dubai however, the file is missing documentation to verify the property expenses. Upon receipt of the missing property expense verifications, additional conditions may apply.

Reviewer Comment (2019-10-04): Received internet printout for RE taxes in XXXXXX and lender;s attestation and calculations for estimated RE taxes and insurance on the XXXXXX property. Buyer Comment (2019-09-18): Online information indicates that no property taxes are charged in XXXXXX.   A Municipality tax is charged based on rental income.   If applying 5% tax to $2100 monthly income, municipality tax would be $105 per month.  Insurance appears to be available for 350 dirhams a month or $95 USD.   If added to total payment and liabilities, the DTI would be 43.92%.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208311499

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Hazard Insurance Policy effective date is XXXXXX which is after the subject loan disbursed on XXXXXX.

Reviewer Comment (2019-10-08): Received Buyer Comment (2019-10-02): please see final ss.  disbursed 6/20

10/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208311499

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311499

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The closing date on the Note, Mortgage and final Closing Disclosure is XXXXXX, but the documents signature date is XXXXXX.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311500

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final Closing Disclosure incorrectly said that the loan is not assumable.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208311500

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 76.56340% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Per XXXXXX Income Calculation Analysis, the co-borrower was qualified with monthly income of $25,000.00 based on a XXXXXX position with XXXXXX  effective XXXXXX. However, this contract was not provided in the file. Therefore, income from the recent paystubs with XXXXXX  has been utilized as the Work Number verifies the co-borrower is still employed there. Co-borrower's verified income is $5,000.67, which results in a DTI of 76.56%.

Reviewer Comment (2019-10-04): Received the co-borrower's new XXXXXX contract to verify monthly income of $25,000.00.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208311500

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Per XXXXXX Income Calculation Analysis, the co-borrower was qualified with monthly income of $25,000.00 based on a XXXXXX  position with XXXXXX  effective XXXXXX. However, this contract was not provided in the file. Therefore, income from the recent paystubs with XXXXXX  has been utilized as the Work Number verifies the co-borrower is still employed there. Co-borrower's verified income is $5,000.67, which results in a DTI of 76.56%.

Reviewer Comment (2019-10-04): Received the co-borrower's new XXXXXX contract to verify monthly income of $25,000.00. Buyer Comment (2019-09-17): Please see contract uploaded under "General ATR Provision" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208311500

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to missing the co-borrower's new employment  contract and a DTI of 76.56%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-04): Received the co-borrower's new XXXXXX contract to verify monthly income of $25,000.00. Buyer Comment (2019-09-17): Please see contract uploaded under "General ATR Provision" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208311500

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Due to missing the co-borrower's new employment  contract and a DTI of 76.56%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-04): Received the co-borrower's new XXXXXX contract to verify monthly income of $25,000.00. Buyer Comment (2019-09-17): Please see contract uploaded under "General ATR Provision" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208311500

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Co-borrower is a wage earner. XXXXXX Full Doc guidelines require the income to be verified with paystubs and the most recent W-2. Paystubs were provided however, the file is missing the required XX W-2.

Reviewer Comment (2019-10-04): Received the co-borrower's XX W-2. new XXXXXX contract to verify monthly income of $25,000.00.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208311500

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: 1003 Final is incomplete

Upon further review of the loan file, the co-borrower's signed Final 1003 is missing from the file and is required to clear this exception.

Reviewer Comment (2019-10-08): Received Buyer Comment (2019-10-07): 1003

10/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208311501

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311501

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

There are Seller paid fees reflected on the Borrower's final Closing Disclosure, but a Seller's Closing Disclosure is missing.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311501

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Borrower was qualified with 24 months personal bank statement income however, only 23 months of statements were provided. File is missing the April XX statement.

Reviewer Comment (2019-10-03): Received the April XX statement.

10/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208311502

XXXXXX

XXXXXX

Credit

Missing Document

General

Incomplete Document: 1003 Final is incomplete

File is missing the signed Final 1003 for the co-borrower.

Reviewer Comment (2019-10-04): Received the co-borrower's signed Final 1003.

10/04/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

B

A

A

A

A

N/A

N/A

No

208311502

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrowers were qualified with rental income for the property at XXXXXX , which was not reported on Schedule E and the file is missing the current lease agreement. The rental income for this property has therefore been excluded which results in a DTI of 60.30%.

Amount of residual income: $17,543 PITIA reserves above minimum by 6 months or greater. Number of PITIA Reserves: 106.1 FICO score above minimum by 20 points or greater. FICO: 763

Originator Originator Originator

Reviewer Comment (2019-10-08): Waived with comp factors Buyer Comment (2019-10-04): Previous document uploaded to wrong file.   Apologies. Reviewer Comment (2019-10-04): Received the lease agreement and verification of the security deposit for this property. Per XXXXXX income worksheet, borrower was qualified with a DTI of 54.87%. Calculated DTI is 53.31%. A lender approved exception with verified compensating factors related to the borrower's ability to repay is required to allow the DTI of 53.31% and waive this exception.

10/08/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

B

A

A

A

A

N/A

N/A

No

208311503

XXXXXX

XXXXXX

Property

Appraisal Reconciliation

Value Discrepancy

Loan is to go in a securitization and reflects only one valuation product when two are required.

File is missing the secondary valuation required for securitization.

Reviewer Comment (2019-09-20): Received the ProTeck Desk Review which returned an inconclusive value of $0.00 and a Desk-Top Review that validates the original appraised value of $XXXXXXX Buyer Comment (2019-09-16): Last outstanding exception shown was for Cash Out exceeds guidelines.   I have uploaded the exception under the requirement for second valuation as the exception for cash out no longer appears and the valuation exception appears twice.

09/20/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208311503

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final Closing Disclosure incorrectly said that the loan is not assumable.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208311503

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The Closing Date on the Final Closing Disclosure is one day before the transaction date.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208311503

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Right to Cancel was executed by the borrowers on XXXXXX with expiration of rescission period noted as XXXXXX. Final Closing Disclosure disclosed a disbursement date of XXXXXX, only providing borrowers with a 2 day rescission period.

Reviewer Comment (2019-10-10): Received Buyer Comment (2019-10-02): please see fss uploaded

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208311503

XXXXXX

XXXXXX

Compliance

Compliance

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 Cancel occurs prior to expected date(s).

Notice of Right to Cancel was executed by the borrowers on XXXXXX with an with expiration of rescission period noted as XXXXXX, which is prior to the expected date based on the borrowers signature of XXXXXX.

Reviewer Comment (2019-10-10): Received Buyer Comment (2019-10-02): please see final ss. loan disbursed on X/XX

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208311503

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

The Hazard Insurance premium includes the past dues amount,

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208311503

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Total cash-out discrepancy.

HUD-1 total cash-out of ___ is greater than Guideline total cash-out of ___.

Borrowers received $662,723.59 total cash back at closing, which exceeds the Full Doc guideline maximum of $500,000.00. File is missing the lender's approved exception with verified compensating factors to allow the excessive cash out.

Borrowers have residual income of $19,927.82 36.46% DTI on this Bank Statement documentation loan < 50.00% guideline max - 13.54% below program guideline maximum

Originator Originator

Reviewer Comment (2019-09-20): Lender approved exception to allow cash out exceeding the guideline max of $500,000.00.

09/20/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208311504

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

Subject loan closed with an LTV of 80.00%, which exceeds the Bank Statement guideline maximum LTV of 75.00% for an investment cash-out refinance. File is missing a lender approved exception with verified compensating factors to allow the higher LTV on an investment cash-out refinance.

Housing payment history clean for 32 months Borrower has residual income of $29,047.29 22.45 months reserves > 10 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow the LTV of 80%, which exceeds the guideline max of 75% for an investment cash-out refinance. Buyer Comment (2019-09-17): Paragraph #22. on Page 7 of the lease agreement shows that A. This lease is automatically renewed.  B. At the end of this Lease Agreement, this lease will continue in full force and effect on a month to month basis unless Tenant or Landlord provides written notice to the other party at least 30 days before the end of term.   Per online information available, XXXX is not available for sale or for lease.

10/04/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

B

A

A

A

A

N/A

N/A

No

208311504

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrower was qualified with the vacancy method for the property at XXXXXX  however, the lease agreement in the file expired on XXXXXX prior to the subject loan closing on XXXXXX. An updated or new lease agreement was not provided. Schedule E was used to validate the net rental loss which results in a DTI of 51.41%.

Housing payment history clean for 32 months Borrower has residual income of $29,047.29 22.45 months reserves > 10 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-10-10): Waived with comp factors Buyer Comment (2019-10-07): exception Reviewer Comment (2019-10-04): Received a duplicate lease agreement to the one already in the file and a Realtor.com printout. This printout cannot be used to verify current rent on the subject property when the lease agreement expired on XXXXXX. A current signed lease agreement effective XXXXXX for XXXXXX is required to clear this exception, or a lender approved exception with verified compensating factors related to the borrower's ability to repay is required to allow the DTI of 51.41% and waive this exception. Buyer Comment (2019-09-17): Paragraph #22. on Page 7 of the lease agreement shows that A. This lease is automatically renewed.  B. At the end of this Lease Agreement, this lease will continue in full force and effect on a month to month basis unless Tenant or Landlord provides written notice to the other party at least 30 days before the end of term.   Per online information available, XXXXXX is not available for sale or for lease.

10/10/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

B

A

A

A

A

N/A

N/A

No

208311505

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311505

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 51.32177% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Per XXXXXX Income Calculation Analysis, the borrower was qualified with a DTI of 52.63% which exceeds the Full Doc guideline maximum DTI of 50.00%. Calculated DTI is 51.32%. File is missing the lender approved exception with verified compensating factors related to the borrower's ability to repay to allow a DTI above 50.00%.

Borrowers have residual income of $8,812.43 54.62 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI up to 52.65%, above the guideline max of 50%. Buyer Comment (2019-09-17): Please see exception uploaded under "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311505

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Per XXXXXX Income Calculation Analysis, the borrower was qualified with a DTI of 52.63% which exceeds the Full Doc guideline maximum DTI of 50.00%. Calculated DTI is 51.32%. File is missing the lender approved exception with verified compensating factors related to the borrower's ability to repay to allow a DTI above 50.00%.

Borrowers have residual income of $8,812.43 54.62 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI up to 52.65%, above the guideline max of 50%.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311505

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 52.63%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI up to 52.65%, above the guideline max of 50%. Buyer Comment (2019-09-17): Please see exception uploaded under "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311505

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Due to a DTI of 52.63%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI up to 52.65%, above the guideline max of 50%. Buyer Comment (2019-09-17): Please see exception uploaded under "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311505

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Total cash-out discrepancy.

HUD-1 total cash-out of ___ is greater than Guideline total cash-out of ___.

Borrowers received $553,341.55 total cash out at closing, which exceeds the Full Doc guideline maximum of $500,000.00. File is missing the lender's approved exception with verified compensating factors to allow the excessive cash out.

Borrowers have residual income of $8,812.43 54.62 months reserves > 6 months guideline minimum

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow cash back of $553,341.55, which exceeds the guideline max of $500,000.00.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311506

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Verified reserves of 5.57 are insufficient to cover the guideline required reserves of 6 months. XXXXXX Income Calculation Analysis noted an exception was required for reserves. However file is missing the lender approved exception with verified compensating factors to allow less than the required 6 months of reserves.

Borrower has residual income of $6,431.90 Housing payment history clean for 52 months

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow 5.57 months reserves when the guidelines require 6 months. Buyer Comment (2019-09-17): Please clarify exception.   Worksheet reflects income of $12,541.75 with expenses at $5100 for primary residence and $975 for liabilities resulting in 40.66/48.44% ratios.  XXXXXX has positive cash flow of $243 using current lease agreement for gross rents and applying to Schedule E for expenses and depreciation. (See Page 2 of attachment).    $243 positive cash flow from REO is not used in qualifying income.

10/04/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

B

A

A

A

A

N/A

N/A

No

208311506

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insufficient Coverage: Hazard insurance coverage amount is insufficient.

Hazard insurance amount of $587,000.00 is not enough to cover the loan amount of XXXXXX or appraisal replacement cost of $xxxxx. File is missing the insurance company replacement cost estimator to verify that the amount of coverage is sufficient.

Reviewer Comment (2019-10-04): Received the replacement cost estimator. Buyer Comment (2019-10-02): please see eoi estimator

10/04/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

B

A

A

A

A

N/A

N/A

No

208311507

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects assumption is not allowed.

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311507

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

An amount was not disclosed as a cure for undisclosed Entity Review fee.

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311507

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Administration Fee.  Fee Amount of $250.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Entity Review Fee (Administration Fee) was not disclosed on the Initial Loan Estimate dated XXXXXX, but disclosed as $250.00 on the revised Closing Disclosure dated XXXXXX and on the Final Closing Disclosure. Evidence of cure for the increase of $250.00 was not provided.

Reviewer Comment (2019-10-07): AMC received 0617 COC. Exception Cleared. Buyer Comment (2019-10-03): Please see email showing valid coc reason

10/07/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311508

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing the borrower's full Fraud Report.

Reviewer Comment (2019-09-17): Received

09/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208311508

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Non-Assumability Rider to the Note was not provided at the time of audit review.

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208311508

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Consumer(s) Final CD disclosed Closing Date XXXXXX, however consummation took place on XXXXXX as indicated by wet signature(s).

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208311508

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cash to Close table did not indicate the dollar figure for exceeded legal limit amount; no cure given to Consumer(s).

Reviewer Comment (2019-09-12): Waive per client request.

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208311508

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $685.00.  Insufficient or no cure was provided to the borrower.

Appraisal Fee was disclosed as $685.00 on the Initial Loan Estimate dated XXXXXX, but disclosed as $700.00 on the Final Closing Disclosure. Evidence of cure for the increase of $15.00 was not provided.

Reviewer Comment (2019-10-07): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided.  See newly added exception for cure. Buyer Comment (2019-10-03): please see pccd and cure

10/07/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208311508

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $700.00 exceeds tolerance of $685.00.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD provided.

Reviewer Comment (2019-10-07): Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208311509

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

The XX automatic tax return extension request was found in file however, the XX tax return was not signed.

Reviewer Comment (2019-09-13): Waive per client request.

09/13/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208311509

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

The XX automatic tax return extension request was found in file however, the XX tax return was not signed.

Reviewer Comment (2019-09-13): Waive per client request.

09/13/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208311509

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

The XX automatic tax return extension request was found in file however, the XX tax return was not signed.

Reviewer Comment (2019-09-13): Waive per client request.

09/13/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208311509

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Final CD loan assumption verbiage does not match the subject Note loan assumption language as required.

Reviewer Comment (2019-09-13): Waive per client request.

09/13/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311509

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The Final CD was dated XXXXXX however loan documents were not signed by the borrowers until XXXXXX.

Reviewer Comment (2019-09-13): Waive per client request.

09/13/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311509

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date

Truth in Lending Act:  Subject loan transaction disbursed on XXXXXX, prior to three (3) business days from transaction date of XXXXXX

Right to Cancel was executed by the borrowers on XXXXXX. The document date was changed to XXXXXX and the rescission period expiration was changed to XXXXXX with the changes initialed by the borrowers. However, the Final Closing Disclosure disclosed a disbursement date of XXXXXX, only providing the borrowers with a 2 day rescission period.

Reviewer Comment (2019-10-10): Received Buyer Comment (2019-10-03): please see the final ss.  loan disbursed 6/26

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Rate/Term

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208311510

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Non-Assumability Rider to the Note was not provided at the time of audit review.

Reviewer Comment (2019-09-11): Waive per client request.

09/11/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311510

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrowers were qualified with rental income for the property at XXXXXX . The borrowers most recent tax return including Schedule E was not provided, and the file is missing the current lease agreement. The rental income for this property has therefore been excluded which results in a DTI of 54.71%.

Borrowers have residual income of $10,837.75 Housing payment history clean for 37 months

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI of 54.71% which exceeds the guideline max of 50%.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311510

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 54.70935% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrowers were qualified with rental income for the property at XXXXXX . The borrowers most recent tax return including Schedule E was not provided, and the file is missing the current lease agreement. The rental income for this property has therefore been excluded which results in a DTI of 54.71%.

Borrowers have residual income of $10,837.75 Housing payment history clean for 37 months

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI of 54.71% which exceeds the guideline max of 50%. Buyer Comment (2019-09-17): Please see "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311510

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Due to missing a current lease agreement to verify rental income and a DTI of 54.71%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI of 54.71% which exceeds the guideline max of 50%. Buyer Comment (2019-09-17): Please see "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311510

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to missing a current lease agreement to verify rental income and a DTI of 54.71%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI of 54.71% which exceeds the guideline max of 50%. Buyer Comment (2019-09-17): Please see "Investor qualifying total debt ratio discrepancy" tab.

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311511

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1 - October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of 11,369.28 on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Estimated Property Costs over Year 1 of $11,369.28. Estimated Property Costs are $945.45 per month, which equates to calculated Escrowed Property Costs over Year 1 of $11,345.40.

Reviewer Comment (2019-10-09): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-10-08): please see pccd 2 and delivery Reviewer Comment (2019-10-07): AMC reviewed exception. The allowable tolerance for the escrow account fields on page four of the CD is $0.02 per month of property costs or $0.24 for 12 months. Total disclosed on page four of CD for Total Property Costs is $11345.40 and documentation in images indicates total should be $11347.47or $10401.85 ($10169.32 Taxes and $1178.15) Please provide verification if using an updated amount.  Letter of Explanation and Corrected CD required to cure. Buyer Comment (2019-10-03): please see pccd and delivery

10/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208311511

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Note provided reflects loan is assumable.  Final CD shows not assumable.

Reviewer Comment (2019-09-13): Waive per client request.

09/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208311511

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrowers were qualified with a DTI is 51.44%. Calculated DTI is 51.47%.

Housing payment history clean for 40 months Borrowers have residual income of $8,821.17

Originator Originator

Reviewer Comment (2019-09-13): Lender approved exception to allow a DTI above the guideline max of 50% with comp factors noted.

09/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208311511

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 51.47244% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrowers were qualified with a DTI is 51.44%. Calculated DTI is 51.47%.

Housing payment history clean for 40 months Borrowers have residual income of $8,821.17

Originator Originator

Reviewer Comment (2019-09-13): Lender approved exception to allow a DTI above the guideline max of 50% with comp factors noted.

09/13/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208311530

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Hazard Insurance Policy effective date of XXXXXX is after the subject loan disbursed on XXXXXX.

Reviewer Comment (2019-10-08): Received Buyer Comment (2019-10-02): please see final ss. disbursed 8/7

10/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208311530

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The final CD indicates the loan is not assumable, and the note contains assumption language.

Reviewer Comment (2019-09-30): Waive per client request.

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311540

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure reflects that assumption is not allowed.

Reviewer Comment (2019-10-03): Waive per client request.

10/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311540

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The Final CD showed closing as XXXX19 however the documents were not signed until XXXX19.

Reviewer Comment (2019-10-03): Waive per client request.

10/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311540

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

The Index Value used is causing a discrepancy between the calculated Total Interest Percentage and the Total Interest Percentage disclosed on the final Closing Disclosure.  The amount disclosed on the Closing Instructions causes a discrepancy as well.

Reviewer Comment (2019-10-03): Waive per client request.

10/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311541

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing the borrower's full Fraud Report.

Reviewer Comment (2019-10-08): Received

10/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208311541

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure disclosed that assumption is not allowed.

Reviewer Comment (2019-10-04): Waive per client request.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311542

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Note contains assumption language.

Reviewer Comment (2019-10-04): Waive per client request.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

B

B

B

B

A

A

Non QM

Non QM

Yes

208311542

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___

Borrower was qualified with business bank statement income with bank statements dated from XXXXXX through XXXXXX. XXXXXX guidelines require the P&L to be dated the same time period as the bank statements. P&L provided in the file has an ending date of XXXXXX instead of XXXXXX. A P&L statement with the correct ending date and signed by the borrower prior to closing is required to clear this exception.

Borrower has residual income of $23,649.06 34.50% DTI on this Bank Statement documentation loan < 50.00% guideline max - 15.50% below program guideline maximum 117 months reserves > 6 months guideline minimum 75% LTV < 85 guideline max Borrowers made a down payment of $1,777,753 from their own funds on this purchase transaction.

Originator Originator Originator Originator Originator

Reviewer Comment (2019-10-24): Added addtl comp factors Reviewer Comment (2019-10-09): Lender approved exception to allow a P&L Statement for the borrower's business bank statement income with a XX ending date, instead of XX.

10/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

B

B

A

A

Non QM

Non QM

No

208311543

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Verified reserves of 0.89 months are insufficient to cover the guideline required reserves of 8 months for the subject investment and financed primary residence. Verified reserves after closing of $5,316.15 are insufficient to cover the dollar amount required of $44,378.62 (subject investment PITI of $5,542.69 x 6 months = $33,256.14 + primary residence PITI of $5,561.24 x 2 months = $11,122.48. XXXXXX income worksheet qualified the borrower with 100% of the business accounts used for assets however, borrower is 50% owner of the business. Per XXXXXX Underwriting guidelines, available assets will be limited to the borrower's percentage of ownership in the business.

Borrower has a disposable income of $14,686 Borrower has employment stability for 26 years.

Originator Originator

Reviewer Comment (2019-10-08): Waived with comp factors

10/08/2019

2

B

XXXXXX

XXXXXX

Investment

Purchase

C

B

C

B

A

A

A

A

N/A

N/A

No

208311544

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

The monthly escrow payment disclosed on the Initial Escrow Account Disclosure Statement is incorrect at $697.52.  The actual monthly payment is $627.42.

Reviewer Comment (2019-10-05): Waive per client request.

10/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311544

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure disclosed that assumption is not allowed.

Reviewer Comment (2019-10-05): Waive per client request.

10/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311547

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Information was verified per the Final Closing Disclosure provided.

Reviewer Comment (2019-10-07): Waive per client request.

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311548

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Most Recent Tax Return provided for XXXXXX is XXXXXX. XX Tax Extension in file.

Reviewer Comment (2019-10-07): Waive per client request.

10/07/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208311548

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Most Recent Tax Return provided for XXXXXX is XXXXXX; the application is date after tax due date. XX Tax Extension in file.

Reviewer Comment (2019-10-07): Waive per client request.

10/07/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208311548

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Most Recent K-1 provided for xxxxx is XXXXXX; the application  is date after tax due date. Proof of XX tax extension was not provided.

Reviewer Comment (2019-10-07): Waive per client request.

10/07/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208311548

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Missing Non-Assumability Rider

Reviewer Comment (2019-10-07): Waive per client request.

10/07/2019

2

B

XXXXXX

XXXXXX

Second Home

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311551

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

Reviewer Comment (2019-10-07): Waive per client request.

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311551

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure disclosed that assumption is not allowed.

Reviewer Comment (2019-10-07): Waive per client request.

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311553

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Reviewer Comment (2019-10-08): EV2 waived at client request

10/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208311553

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Note verbiage indicates the loan is assumable. Final CD page 4 reflects loan is not assumable. Missing Non-Assumability Rider.

Reviewer Comment (2019-10-08): EV2 waived at client request

10/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311553

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Bank Statement program requires a P&L Statement AND a minimum of 3 months Business Bank Statements in addition to Personal Bank Statements. Required income documents are missing.

24 months Bank statements was used for income qualification. June and July XX bank statements for business account used for qualification are missing from file.  Used June XX to make 23 months. Unable to calculate final income.

Reviewer Comment (2019-10-10): Received

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208311553

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final CD reflects a closing date of XXXXXX.  Loan signed XXXXXX.

Reviewer Comment (2019-10-08): EV2 waived at client request

10/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208311556

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Divorce Decree / Child Support not provided

Borrower was qualified with alimony and child support payments however, file is missing the divorce decree and child support order to verify the monthly amounts. Upon receipt of the missing divorce decree and child support order, additional conditions may apply.

Reviewer Comment (2019-10-10): Received

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311556

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

Subject purchase is a non-arms length transaction and file contains a Gift letter for the Gift of Equity from the seller of the subject property to the borrowers however, the gift letter does not reflect the relationship between seller and borrower. Per XXXXXX Underwriting guidelines, a gift can be provided by a relative, defined as the borrower's spouse, child, or other dependent or by any other individual who is related to the borrower by blood, marriage, adoption, or legal guardianship, a fiancé, fiancée, or domestic partner. The donor may not be, or have any affiliation with, the builder, the developer, the real estate agent, or any other interested party to the transaction.

Reviewer Comment (2019-10-10): Received gift letter meeting guidelines

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311556

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note allows for assumption, but the final Closing Disclosure disclosed that assumption is not allowed.

Reviewer Comment (2019-10-08): Waive per client request.

10/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311556

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

There are Seller paid fees disclosed on the Borrower's final Closing Disclosure, but the Seller's Closing Disclosure is missing.

Reviewer Comment (2019-10-08): Waive per client request.

10/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311556

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The closing date disclosed on the Note, Mortgage and final CD is XXXXXX.  However, the Notary signature date is XXXXXX.

Reviewer Comment (2019-10-08): Waive per client request.

10/08/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311556

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Verified reserves of 0 months are insufficient to cover the guideline required reserves of 6 months. Verified reserves after closing of $0.00 are insufficient to cover the dollar amount required of $34,126.56.File contains 1 XXXXXX business bank statement dated XXXXXX in the name of XXXXXX  however, the file is missing the second statement as required by the guidelines and proof the borrowers are owners of this business. Therefore, this account has been excluded.

Reviewer Comment (2019-10-10): Received

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311556

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Verified assets of $71,044.77 are insufficient to cover the funds for closing of $151,222.88. File contains 1 XXXXXX business bank statement dated XXXXXX in the name of XXXXXX however, the file is missing the second statement as required by the guidelines and proof the borrowers are owners of this business. Therefore, this account has been excluded.

Reviewer Comment (2019-10-10): Received Buyer Comment (2019-10-09): Please see documents uploaded under "PITIA reserves months discrepancy" tab.

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311556

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Per XXXXXX Income Calculation Analysis, the borrower was qualified with a DTI of 53.74% which exceeds the Full Doc guideline maximum DTI of 50.00%. Calculated DTI is 53.31%. File is missing the lender approved exception with verified compensating factors related to the borrower's ability to repay to allow a DTI of 53.31%.

Borrower has employment stability for 22 years PITIA reserves above minimum by 6 months or greater. Number of PITIA Reserves: 24.36 700 representative FICO score > 660 guideline minimum

Originator Originator Originator

Reviewer Comment (2019-10-10): Waived with comp factors

10/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311556

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 53.31379% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Per XXXXXX Income Calculation Analysis, the borrower was qualified with a DTI of 53.74% which exceeds the Full Doc guideline maximum DTI of 50.00%. Calculated DTI is 53.31%. File is missing the lender approved exception with verified compensating factors related to the borrower's ability to repay to allow a DTI of 53.31%.

Borrower has employment stability for 22 years PITIA reserves above minimum by 6 months or greater. Number of PITIA Reserves: 24.36 700 representative FICO score > 660 guideline minimum

Originator Originator Originator

Reviewer Comment (2019-10-10): Waived with comp factors Buyer Comment (2019-10-09): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311556

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Due to a DTI of 53.31%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-10): Updated to Non-QM Buyer Comment (2019-10-09): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208311556

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 53.31%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-10): Updated to Non-QM Buyer Comment (2019-10-09): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208311559

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

The XX tax returns were used, a tax return extension was provided for XX.

Reviewer Comment (2019-10-09): Waive per client request.

10/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208311559

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

The XX tax returns were used, a tax return extension was provided for XX.

Reviewer Comment (2019-10-09): Waive per client request.

10/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208311559

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The Note contains assumption language, and the CD indicates the loan is not assumable.

Reviewer Comment (2019-10-09): Waive per client request.

10/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311559

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Not Provided at or Before Closing (3-Day Waiver In File)

ECOA Valuations Rule (Dodd-Frank 2014): Borrower waived right to receive a copy of the appraisal at least three (3) business days prior to closing, and appraisal was not provided at or before closing.

The file does not contain evidence of the date the appraisal was provided.

Reviewer Comment (2019-10-09): Waive per client request.

10/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208311559

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

The XX tax returns were used, a tax return extension was provided for XX.

Reviewer Comment (2019-10-09): Waive per client request.

10/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208311559

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $900.00 exceeds tolerance of $850.00.  Sufficient or excess cure was provided to the borrower at Closing.

A Cure in the amount of $50.00 was provided at closing.

10/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311560

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

RESPA -  Initial Escrow Account statement Inaccurate

RESPA: Initial escrow account statement does not match charges on HUD-1/Final Closing Disclosure.

The Inital Escrow statement shows and initial deposit of $5821.64, and monthly payments of $957.80. The Final CD has the initial deposit as $5,744.54, and monthly payments of $973.22.

Reviewer Comment (2019-10-10): Waived at client request

10/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311560

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The note contains assumption language, and the Final CD indicates the loan is not assumable.

Reviewer Comment (2019-10-10): Waived at client request

10/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311560

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The closing date listed on the final CD is XXXX19, and the loan closed on XXXX19.

Reviewer Comment (2019-10-10): Waived at client request

10/10/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208311561

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Final CD reflects disbursement date of XXXX18.

Reviewer Comment (2019-09-11): Amended HOI provided with XXXXXX to XXXXXX effective date.  Copy of signed master final closing statement documents a XXXXXX disbursement date. Buyer Comment (2019-09-09): attached is the dec page and final settlement statement Reviewer Comment (2019-09-09): Reopening Buyer Comment (2019-07-19): please withdraw file, unable to clear trid item

09/11/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

Reviewer Comment (2019-05-10): Rec'd fraud report. Buyer Comment (2019-05-10): fraudguard

05/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

Guideline required 6 months. Approval and 1008 show a $50,000.00 gift. There is no documentation showing gift receipt in file.

75% LTV < 90% max. Borrowers have a disposable income of $4,768.26.

Originator Originator

Reviewer Comment (2019-05-17): Rec'd exception for reserves < 6 mos.

05/17/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Disclosure not found in file.

Reviewer Comment (2019-01-23): Attestation approved by AMC in file.

01/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Non QM due to DTI exceeding 50%.  Guides allow 50%, audited DTI is 55.751%. Lender used Note rate of 6.375% to qualify, instead of qualifying rate of 6.62513% resulting in excessive DTI.

Reviewer Comment (2019-10-04): Received, diligence designation updated to Non-QM. Buyer Comment (2019-10-04): please see exception allowing for 54.82% DTI Buyer Comment (2019-10-02): please see atr response Reviewer Comment (2019-10-01): Re-opening per client request Buyer Comment (2019-07-19): please withdraw file, unable to clear

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Final CD reflects not assumable.  Note reflects loan is assumable.

Reviewer Comment (2019-01-23): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller Change - Deposit

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether there was a change in the Deposit. (Final/XXXXXX)

Final CD Calculating Cash to Close table reflects Deposit of ($29,787) on LE and ($29,786.64) on CD - question Did this change? Yes.  Should reflect No as this is not a change as LE reflects figure round up or down to nearest dollar amount.

Reviewer Comment (2019-01-23): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file. (Final/XXXXXX)

Seller CD not evidenced in loan file.

Reviewer Comment (2019-01-23): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Loan Origination Fee.  Fee Amount of $15,630.00 exceeds tolerance of $14,880.00.  Insufficient or no cure was provided to the borrower. (7325)

Change of circumstance in file dated XXXXXX does not reflect a valid reason.

Reviewer Comment (2019-10-04): Received this e-mail request from XXXXX on XXXXXX: " "Also, regarding the tolerance cure, we do not see that as something we can clear due to the finding date being past 60 days." Exception remains an uncurable EV3. Buyer Comment (2019-10-02): please see atr response uploaded Reviewer Comment (2019-10-01): Re-opening per client request Buyer Comment (2019-07-19): unable to cure.  past 60 days

3

C

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit. (Final/XXXXXX)

Final CD does not reflect an amount by which total closing costs exceeded the legal limit.  Should reflect $750.

Reviewer Comment (2019-01-23): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

B

C

C

A

A

Non QM

Non QM

Yes

208311561

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Lender qualified based on Note rate not the greater of the note rate or the fully indexed rate (margin + index) amortized over 30 years

Housing payment history clean for 25 months Borrowers have a disposable income of $4,768.26.

Originator Originator

Reviewer Comment (2019-10-04): Received documentation that reduced the DTI to 54.82%. Buyer Comment (2019-10-02): please see atr response uploaded Reviewer Comment (2019-10-01): Re-opening per client request Buyer Comment (2019-07-19): please withdraw file, unable to clear trid item

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to DTI being over 55%.

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI of 54.82% which exceeds the guideline max of 50%. Buyer Comment (2019-10-02): please see atr response uploaded Reviewer Comment (2019-10-01): Re-opening per client request Buyer Comment (2019-07-19): please withdraw file, unable to clear

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 54.82313% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Lender qualified at Note rate not the greater of the note rate or the fully indexed rate (margin + index) amortized over 30 years

Housing payment history clean for 25 months Borrowers have a disposable income of $4,768.26.

Originator Originator

Reviewer Comment (2019-10-04): Waived with comp factors noted Reviewer Comment (2019-10-04): Updated from: Ability to Repay (Dodd-Frank XX): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 55.75111% moderately exceeds the guideline maximum of 55.00%. (DTI Exception is eligible to be regraded with compensating factors.) Reviewer Comment (2019-10-01): Guides allow 50%, audited DTI is 55.751% Reviewer Comment (2019-10-01): Re-opening per client request Buyer Comment (2019-07-19): please withdraw file, unable to clear trid item

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

Borrower does not have a 1 year history of employment.  Date of hire at current employment is XXXX18.  Prior to that he was unemployed since XX2014.  LOE in file states unemployment due to health and family matters.

Housing payment history clean for 25 months Borrowers have a disposable income of $4,768.26.

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow a 1-year employment history with borrower unemployed prior to that, when the guidelines require 2 years. Buyer Comment (2019-10-02): please see exception Reviewer Comment (2019-10-01): Re-opening per client request Buyer Comment (2019-07-19): please withdraw file, unable to clear trid item

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 55.75111% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Housing payment history clean for 25 months Borrowers have a disposable income of $4,768.26.

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI of 54.82% which exceeds the guideline max of 50%. Buyer Comment (2019-10-02): please see atr response

10/04/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311561

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Received documentation that reduced the DTI to 54.82%.

Housing payment history clean for 25 months Borrowers have a disposable income of $4,768.26.

Originator Originator

Reviewer Comment (2019-10-04): Lender approved exception to allow a DTI of 54.82% which exceeds the guideline max of 50%.

10/04/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

B

C

C

A

A

Non QM

Non QM

No

208311563

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Approval not provided

Lender approval not evidenced in loan file.

Reviewer Comment (2019-04-05): Approval provided.

04/05/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

208311563

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (1st Lien, Escrow Not Established)

Federal Higher-Priced Mortgage Loan (XXXX): Mandatory escrow account not established on 1st lien mortgage loan.

Reviewer Comment (2019-10-07): Per XXXXXX e-mail on XXXXXX: "We agree that the 2 hpml cannot be cured." Reviewer Comment (2019-09-19): Our compliance department has rereviewed this exception with this response: "HPML determination is based on APR exceeding the applicable HPML rate threshold.  Both the calculated and disclosed APR exceed the HPML threshold.  Lender's HPML analysis in file shows the same HPML threshold SitusAMC used (6.440%) and the calculated APR of 6.4790% as well as the lender's disclosed APR on both XX16 final CD (6.4770%) and XX26 PCCD (6.444%) all exceed the HPML threshold.   Exception remains." Reviewer Comment (2019-09-18): This exception has been escalated to our compliance department for review. Buyer Comment (2019-09-04): please see fss uploaded Reviewer Comment (2019-04-18): The High Cost provided shows APR of 6.4378% however the APR on the final CD is 6.477%. Reviewer Comment (2019-04-05): Testing still showing as HPML, please provide missing rate lock for further updates. Buyer Comment (2019-04-04): we don't show that the loan is HPML

3

C

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

208311563

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.47900% or Final Disclosure APR of 6.47700% is in excess of allowable threshold of APOR 4.94% + 1.5%, or 6.44000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-10-07): Per XXXXXX e-mail on XXXXXX: "We agree that the 2 hpml cannot be cured." Reviewer Comment (2019-09-19): Our compliance department has rereviewed this exception with this response: "HPML determination is based on APR exceeding the applicable HPML rate threshold.  Both the calculated and disclosed APR exceed the HPML threshold.  Lender's HPML analysis in file shows the same HPML threshold SitusAMC used (6.440%) and the calculated APR of 6.4790% as well as the lender's disclosed APR on both XX16 final CD (6.4770%) and XX26 PCCD (6.444%) all exceed the HPML threshold.   Exception remains." Reviewer Comment (2019-09-18): This exception has been escalated to our compliance department for review. Buyer Comment (2019-09-03): Please see final ss.  Loan is not HPML Reviewer Comment (2019-08-06): Updated from: Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.47220% or Final Disclosure APR of 6.47700% is in excess of allowable threshold of APOR 4.94% + 1.5%, or 6.44000%.  Non-Compliant Higher Priced Mortgage Loan.

3

C

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

208311563

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Reviewer Comment (2019-01-23): Attestation approved by AMC in file.

01/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

208311563

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Estimated Property Costs over Year 1 of $16,317.48 on Final Closing Disclosure provided on XXXXXX not accurate. (Final/XXXXXX)

Included in escrow amount is HOA dues monthly $440 and HO6 $5 monthly for a total of $5880.

Reviewer Comment (2019-10-07): Cure documentation provided Reviewer Comment (2019-10-07): Cure documentation received. Reviewer Comment (2019-08-06): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-07-16): PCCD dated XXXX18 provided.  Need LOE to cure. Buyer Comment (2019-07-15): see the final cd that was given to the borrower at loan disbursement … the master policy has walls in there is no HO6 policy

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

208311563

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption. (Final/XXXXX)

Note and Security instrument have language that loan may have assumption permission under certain conditions, the CD states no assumption is permitted. No separate Borrower signed acknowledgement that assumption is not permitted contained in file.

Reviewer Comment (2019-01-23): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

208311563

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on  XXXXXX disclosed a Closing Date that did not match the actual date of consummation. (Final/ XXXXXX)

Final CD reflects closing date of XXXX18.  Loan was consummated on XXXX18.

Reviewer Comment (2019-01-23): Waive per client.

01/23/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

208311563

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure Contains Fees not reflected on Consumer's Final Closing Disclosure

TILA-RESPA Integrated Disclosure: the Seller's final CD contained fees not reflected on the consumer's CD. (Final/XXXXXX)

TRID non-compliant.  Seller paid fees on Seller CD are not consistent with those on Borrower Final CD.  Seller CD reflects $94,850 in seller paid fees.  Borrower CD reflects $7,361.56 in seller paid fees.

Reviewer Comment (2019-08-06): 60 day window to cure has expired, per client moving to Waive as EV3

08/06/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

208311563

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

Missing Document: Hazard Dec Page not provided

Missing HO6 policy.

Reviewer Comment (2019-04-12): Policy does cover walls in as stated on page 5. Buyer Comment (2019-04-11): the master policy covers the walls in so there is no policy that is required from the borrower

04/12/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

C

C

A

C

C

A

A

Non QM

Non QM

No

208311563

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan. (XXXXXX)

Final CD reflects finance charge of $xxxxx.  Calculated finance charge is $xxxxx.

Reviewer Comment (2019-08-06): 60 day window to cure has expired, per client moving to Waive as EV3 Reviewer Comment (2019-07-17): Calculated finance charge on PCCD issued on XXXX18 is $xxxx a under-disclosure of $580.00 needs to be refunded.  A Corrected CD, copy of refund check, letter of explanation and proof of delivery is required to cure. Buyer Comment (2019-07-16): the Final CD dated 11.26.19 has a finance charge of $xxx Reviewer Comment (2019-07-16): Calculated Finance Charge on PCCD issued on XXXX18 is xxxx a difference of -$580.00 from finance charge on PCCD of $xxxx.  To cure a Corrected CD, Copy of Refund check for under-disclosed amount, Letter of Explanation and Proof of Delivery are required. Buyer Comment (2019-07-15): see the final cd that was given to the borrower at loan disbursement … the escrow fee was split as the seller paid for their own ..

08/06/2019

3

C

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

C

C

A

C

C

A

A

Non QM

Non QM

Yes

208323422

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

Borrower was qualified with assets that were only verified with 1 statement ending on XXXXXX. XXXXXX guidelines require the most recent 2 months of statements. File is missing the May statements for all accounts. Upon receipt of the missing bank statements, additional conditions may apply.

FICO score above minimum by 20 points or greater. FICO: 770 DTI below max by 5% or greater. DTI: 39.63% 54% LTV < 70% guideline max

Originator Originator Originator

Reviewer Comment (2019-10-11): Waived with comp factors

10/11/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Cash-out - Other

C

B

C

B

A

A

A

A

N/A

N/A

No

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

The final CD indicates the loan is not assumable, and the Note contains assumption language.

Reviewer Comment (2019-09-30): Waive per client request.

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The final CD disclosed the closing date as XXXX19, and the loan closed om XXXX19.

Reviewer Comment (2019-09-30): Waive per client request.

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Escrowed Property Costs Year 1 -  October 2018 Test

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Escrowed Property Costs over Year 1 of XXXXXX on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Estimated Property Costs over Year 1 of $18,634.08. Estimated Property Costs are $1,652.89 per month, which equates to calculated Escrowed Property Costs over Year 1 of $19,834.68. Post-closing CD dated XXXXXX disclosed the correct  Escrowed Property Costs over Year 1 of $19,834.68 however, the file is missing the Letter of Explanation to the borrower which is required to cure this exception.

Reviewer Comment (2019-10-07): AMC received PCCD correcting escrow amount and LOE. Exception Cured. Buyer Comment (2019-10-03): please see pccd delivery

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 1 that does not match the actual payment for the loan.

Final Closing Disclosure disclosed an Estimated Escrow Payment for Payment Stream 1 of $1,552.84; calculated  Estimated Escrow Payment is $1,652.89. Post-closing CD dated XXXXXX disclosed the correct Estimated Escrow Payment of $1,652.89 however, the file is missing the Letter of Explanation to the borrower and Proof of Delivery which are required to cure this exception.

Reviewer Comment (2019-10-07): AMC received PCCD correcting escrow amount and LOE. Exception Cured. Buyer Comment (2019-10-03): please see pccd delivery uploaded

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 2 that does not match the actual payment for the loan.

Final Closing Disclosure disclosed an Estimated Escrow Payment for Payment Stream 2 of $1,552.84; calculated  Estimated Escrow Payment is $1,652.89. Post-closing CD dated XXXXXX disclosed the correct Estimated Escrow Payment of $1,652.89 however, the file is missing the Letter of Explanation to the borrower and Proof of Delivery which are required to cure this exception.

Reviewer Comment (2019-10-07): AMC received PCCD correcting escrow amount and LOE. Exception Cured. Buyer Comment (2019-10-03): please see pccd delivery uploaded

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 3 that does not match the actual payment for the loan.

Final Closing Disclosure disclosed an Estimated Escrow Payment for Payment Stream 3 of $1,552.84; calculated  Estimated Escrow Payment is $1,652.89. Post-closing CD dated XXXXXX disclosed the correct Estimated Escrow Payment of $1,652.89 however, the file is missing the Letter of Explanation to the borrower and Proof of Delivery which are required to cure this exception.

Reviewer Comment (2019-10-07): AMC received PCCD correcting escrow amount and LOE. Exception Cured. Buyer Comment (2019-10-03): please see pccd delivery uploaded

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Escrow Payment Test

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an escrow payment for payment stream 4 that does not match the actual payment for the loan.

Final Closing Disclosure disclosed an Estimated Escrow Payment for Payment Stream 4 of $1,552.84; calculated  Estimated Escrow Payment is $1,652.89. Post-closing CD dated XXXXXX disclosed the correct Estimated Escrow Payment of $1,652.89 however, the file is missing the Letter of Explanation to the borrower and Proof of Delivery which are required to cure this exception.

Reviewer Comment (2019-10-07): AMC received PCCD correcting escrow amount and LOE. Exception Cured. Buyer Comment (2019-10-03): please see pccd delivery uploaded

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

Final Closing Disclosure disclosed an Estimated Total Monthly Payment for Payment Stream 1 of $XXXXX; calculated  Estimated Total Monthly Payment is $XXXXX. Post-closing CD dated XXXXXX disclosed the correct Estimated Total Monthly Payment of $XXXXX however, the file is missing the Letter of Explanation to the borrower and Proof of Delivery which are required to cure this exception.

Reviewer Comment (2019-10-07): AMC received PCCD correcting escrow amount and LOE. Exception Cured. Buyer Comment (2019-10-03): please see pccd delivery uploaded

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Will Have Escrow -  Initial Escrow Payment

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX disclosed the Initial Escrow Payment that does not match the escrow payment disclosed on page 2.

Post-closing CD dated XXXXXX disclosed the correct Initial Escrow Payment of $1,652.89 however, the file is missing the Letter of Explanation to the borrower which is required to cure this exception.

Reviewer Comment (2019-10-07): AMC received PCCD correcting escrow amount and LOE. Exception Cured. Buyer Comment (2019-10-03): please see pccd delivery uploaded

10/07/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Borrower was qualified with asset depletion income of $7,828.00 which included XXXXXX  however, privately held stock is not allowed to be depleted without an exception approval. In addition, the verification of the current value of the stock shares was not provided. Calculated depletion income is $6,347.23, which results in a DTI of 53.39%. File is missing a lender approved exception with verified compensating factors related to the borrower's ability to repay to 1) allow the privately held stock to be depleted along with verification of the current stock value or 2) allow the DTI of 53.39%.

Amount of residual income: $13,368 FICO score above minimum by 20 points or greater. FICO: 800 PITIA reserves above minimum by 6 months or greater. Number of PITIA Reserves: 63.91

Originator Originator Originator

Reviewer Comment (2019-10-14): Waived with comp factors

10/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 53.38963% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Borrower was qualified with asset depletion income of $7,828.00 which included XXXXXX  however, privately held stock is not allowed to be depleted without an exception approval. In addition, the verification of the current value of the stock shares was not provided. Calculated depletion income is $6,347.23, which results in a DTI of 53.39%. File is missing a lender approved exception with verified compensating factors related to the borrower's ability to repay to 1) allow the privately held stock to be depleted along with verification of the current stock value or 2) allow the DTI of 53.39%.

Amount of residual income: $13,368 FICO score above minimum by 20 points or greater. FICO: 800 PITIA reserves above minimum by 6 months or greater. Number of PITIA Reserves: 63.91

Originator Originator Originator

Reviewer Comment (2019-10-14): Waived with comp factors Buyer Comment (2019-10-02): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/14/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Due to asset depletion income included unallowed privately held stock and a DTI of 53.39%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-14): Updated to Non-QM Buyer Comment (2019-10-02): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208338379

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to asset depletion income included unallowed privately held stock and a DTI of 53.39%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-14): Updated to Non-QM Buyer Comment (2019-10-02): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/14/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208358908

XXXXXX

XXXXXX

Credit

Credit

Credit Report

Borrower has less than 2 FICO scores

Lender exception B-1 XXXX has only one credit score, co-borrower has the great income for this program and will be qualifying for credit score. used B-2. comp factors: LTV 64.789% Program requires 70% Credit score - XXX  program  620 reserves 4 months _Program  requires 3 mos.

No Public records Borrower has been in the same line of business for the past 20 years. 38.79775% DTI on this (Documentation Type) documentation loan <50% guideline max - 11.20225% below program guideline maximum Reserves are 5.36 months, 2.36 months > program maximum of 3 months. Credit score is 622, 2 points > program maximum of 620. LTV is 64.789%, 5.211% < program maximum of 70%.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-27): Client has elected to waive this exception based on compensating factors.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

B

B

A

A

A

A

Non QM

Non QM

No

208358908

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $670.00 exceeds tolerance of $500.00.  Sufficient or excess cure was provided to the borrower at Closing.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

B

B

A

A

A

A

Non QM

Non QM

Yes

208358909

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Summaries Of Transactions - Cash From To Borrower

TILA-RESPA Integrated Disclosure - Summaries of Transactions: Final Closing Disclosure provided on XXXXXX disclosed an Amount of Cash to Close that does not match the Final value of Cash to Close in the Calculating Cash to Close table.

The amount in the Calculating Cash to Close table is $109,970.77 and the amount in the Summaries of Transactions is $112,550.96.) The difference is $2,580.19. Section K, Line 4, shows this amount as "See attached page for additional information." Page 6 of the CD has Payoffs and Payments. The attached page adds up to $2,723.11 but the amount entered in the CD is $2,580.19

Buyer Comment (2019-09-26): XXXXXX has elected to waive this exception

09/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208358909

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $550.00 exceeds tolerance of $495.00.  Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $550.00 exceeds tolerance of $495.00. Sufficient or excess cure was provided to the borrower at Closing

09/25/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208358910

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 8/XXXX 12:00:00 AM was received.

Initial closing disclosure was electronically received prior to the assume date of the final revised loan estimate

Buyer Comment (2019-09-23): XXXXXX has elected to waive this exception.

09/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208358911

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Loan amount discrepancy.

Note loan amount of ___ exceeds Guideline loan amount of ___.

Lender acknowledged exception to allow loan amount of $xxxxx vs program maximum of $3,000,000

Guideline variance approved by lender at time of origination. Two open mortgages reflect 0x30 since inception of earliest opened XXXXXX. 7 closed mortgages reflect paid as agreed. Perfect credit history since inception of earliest account opened XXXXXX. No public records. Guideline variance approved by lender at time of origination. Borrower has been a self-employed XXXXXX for the past 25 years including XXXXXX Guideline variance approved by lender at time of origination.  Reserves are 278 months and program requirement of 12 months Guideline variance approved by lender at time of origination. Credit score is 786, 66 points > program requirement of 720

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-12): Client elects to waive with compensating factors

09/12/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358911

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

LTV/CLTV <= 5%

Lender acknowledged exception to allow LTV of 74.545% vs. program maximum of 70%

Guideline variance approved by lender at time of origination. Two open mortgages reflect 0x30 since inception of earliest opened XXXXXX. 7 closed mortgages reflect paid as agreed. Perfect credit history since inception of earliest account opened XXXXXX. No public records. Guideline variance approved by lender at time of origination. Borrower has been a self-employed XXXXXX for the past 25 years including XXXXXX Guideline variance approved by lender at time of origination.  Reserves are 278 months and program requirement of 12 months Guideline variance approved by lender at time of origination. Credit score is 786, 66 points > program requirement of 720

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-17): Client elects to waive with compensating factors Reviewer Comment (2019-09-12): Client elects to waive with compensating factors

09/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358911

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

- ___

XX in file. Date of loan is August XX, extension for XX expired Oct. XX

Reviewer Comment (2019-09-16): Agree with lender. New deadline to efile a XX Tax Return is October 15, XX. Buyer Comment (2019-09-13): Borrowers have until October to file for their XX taxes

09/16/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358911

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-17): XXXXXX has elected to waive

09/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358911

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 7/XXXX 12:00:00 AM was received.

Buyer Comment (2019-09-17): XXXXXX has elected to waive

09/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

No Defined Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358911

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Self-Employed Tax Return Recency - ATR

Ability to Repay (Dodd-Frank 2014): Self Employed Tax Returns - The business or personal tax returns provided are not the most recent. Application Date XXXXXX,  Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX

Personal tax returns provided are not the most recent. Application Date XXXXXX, Most Recent Tax Return End Date XXXXXX, Tax Return Due Date XXXXXX.

Buyer Comment (2019-09-17): XXXXXX has elected to waive

09/17/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358911

XXXXXX

XXXXXX

Compliance

Compliance

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 Cancel occurs prior to expected date(s).

NRTC signed XXXX19 and expiration dated listed as XXXX19 prior to expiration date of XXXX19.

Reviewer Comment (2019-09-25): AMC received the corrected NORTC with right to cancel expiration date of 8/XXXX. Buyer Comment (2019-09-25): See attached NOR with recession  date 8/XX19 and see CD attached with a disbursement date of 8/XXXX Reviewer Comment (2019-09-24): Per compliance, rescission expires 3 business days following the latest of the 3 trigger dates (consummation, delivery of NORTC, or delivery of material disclosures (see cite below).  NORTC was received by borrower XXXX on 8/XX19, accordingly, rescission expiration is midnight of 8/XX19 while NORTC form provided shows 8/XX19 with no cross off or corrected reflecting the updated expiration date in light of borrower receiving NORTC at a later time than trustee. As a result of the Rescission Notice having an incorrect rescission expiration date, the Notice is considered defective given that it gives the impression the consumer only had until 8/XX19 in which to rescind, when they actually had until 8/XX19. AMC will exception a loan file with an incorrect rescission expiration date given the requirement to "clearly and conspicuously disclose" the date the rescission period expires under §1026.23(b)(1) and the potential risk for an assignee purchasing a loan that contains a rescission notice with an inaccurate date when relying on the argument that the borrower should have known what "midnight of the third business day following the latest of the three events listed above" actually represents. Under 1026.23(b)(1), "The notice shall be on a separate document that identifies the transaction and shall clearly and conspicuously disclose the following: (i ) The retention or acquisition of a security interest in the consumer's principal dwelling. (ii) The consumer's right to rescind the transaction. (iii) How to exercise the right to rescind, with a form for that purpose, designating the address of the creditor's place of business. (iv) The effects of rescission, as described in paragraph (d) of this section. (v) The date the rescission period expires." To cure, re-open rescission (with proof of delivery) to ensure that the rescission possibility is extinguished. Buyer Comment (2019-09-24): The loan consummated on 8/XXXX, the expiration date for the NORTC is 8/XXXX.

09/25/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

208358912

XXXXXX

XXXXXX

Credit

Insurance

Insurance Documentation

The Blanket Coverage for a Condo does not meet guidelines.

Condo project has fidelity coverage of $650,000 vs. program requirement that fidelity coverage must be at a minimum of 3 months's HOA assessments ($xxxxx).  Approved Lender Exception in file.

No public records. Self-employed for the past 2.15 years as XXXXXX DTI is 24.609%, 18.391% < program requirement of 50% Credit score is 711, 31 points > program maximum of 680. Established project with 108 units in 1 phase completed and marketed for sale XXXXXX.  No pending litigation with 106 units current and 2 units over 60 days.  No commercial space.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-10-01): Client has elected to waive this exception based on compensating factors.

10/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358912

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Unacceptable assets were used for closing or reserves.

Allow down payment to be paid directly from the borrower's business account vs. program requirement business funds must be transferred to borrower's personal account.  Approved Lender Exception in file.

No public records. Self-employed for the past 2.15 years as XXXXXX DTI is 24.609%, 18.391% < program requirement of 50% Credit score is 711, 31 points > program maximum of 680. Established project with 108 units in 1 phase completed and marketed for sale XXXXXX.  No pending litigation with 106 units current and 2 units over 60 days.  No commercial space.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-10-01): Client has elected to waive this exception based on compensating factors.

10/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358912

XXXXXX

XXXXXX

Credit

Borrower and Mortgage Eligibility

Mortgage / Program Eligibility

Guideline Requirement: Loan to value discrepancy.

Calculated loan to value percentage of ___ exceeds Guideline loan to value percentage of ___.

90% LTV exceeds max of 85% allowed for non warrantable condo.  Approved Lender Exception in file.

No public records. Self-employed for the past 2.15 years as XXXXXX DTI is 24.609%, 18.391% < program requirement of 50% Credit score is 711, 31 points > program maximum of 680. Established project with 108 units in 1 phase completed and marketed for sale XXXXXX.  No pending litigation with 106 units current and 2 units over 60 days.  No commercial space.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-10-02): Client has elected to waive this exception based on compensating factors. Buyer Comment (2019-10-02): Please see APPROVED EXCEPTION

10/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358912

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Combined loan to value discrepancy.

Calculated combined loan to value percentage of ___ exceeds Guideline combined loan to value percentage of ___.

90% LTV exceeds max of 85% allowed for non warrantable condo.  Approved Lender Exception in file.

No public records. Self-employed for the past 2.15 years as XXXXXX DTI is 24.609%, 18.391% < program requirement of 50% Credit score is 711, 31 points > program maximum of 680. Established project with 108 units in 1 phase completed and marketed for sale XXXXXX.  No pending litigation with 106 units current and 2 units over 60 days.  No commercial space.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-10-01): Client has elected to waive this exception based on compensating factors.

10/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358912

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-10-01): XXXXXX has elected to waive this exception.

10/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358912

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-10-01): XXXXXX has elected to waive this exception.

10/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358912

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Condo project reserves of 1.657% of annual expenditures vs. 5% of the total expenditures required per guides.  Approved Lender Exception in file.

No public records. Self-employed for the past 2.15 years as XXXXXX DTI is 24.609%, 18.391% < program requirement of 50% Credit score is 711, 31 points > program maximum of 680. Established project with 108 units in 1 phase completed and marketed for sale XXXXXX.  No pending litigation with 106 units current and 2 units over 60 days.  No commercial space.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-10-01): Client has elected to waive this exception based on compensating factors.

10/01/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358914

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-09-27): Receipt of appraisal provided.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208358914

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Total Closing Costs exceeded the legal limit.

Buyer Comment (2019-09-27): XXXXXX has elected to waive this exception

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208358914

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Wire /Funding/ Disbursement Fee.  Fee Amount of $50.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-09-30): Upon further review, the exception is cleared. Buyer Comment (2019-09-26): Wire Transfer Fee is on initial LE Please review

09/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208358914

XXXXXX

XXXXXX

Credit

Asset

Asset Calculation / Analysis

Available for Closing is insufficient to cover Cash From Borrower.

Reviewer Comment (2019-09-27): Updated assets for XXXXXX for closing funds reserves., Buyer Comment (2019-09-26): Heloc advances

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208358914

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of 0.00 is less than Guideline PITIA months reserves of 3.00.

Reviewer Comment (2019-09-27): Updated assets for XXXXXX for closing funds reserves.,

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208358914

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-09-27): Updated Preliminary Title provided. Buyer Comment (2019-09-26): Updated Title

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208358914

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrowers company XXXXXX , came into existence on XXXXXX (35 months) versus program requirement that at least one borrower must have been continually self-employed for three years.

Perfect credit history since inception of earliest account opened XXXXXX. No public records. 26.23724% DTI on this Alt documentation loan < 50% guideline max - 23.76276% below program guideline maximum 752 representative FICO score >680  guideline minimum - 72points above guideline minimum 70% LTV < 80% guideline max

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-25): Client has elected to waive this exception based on compensating factors.

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208358915

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TIL Higher Priced Mortgage Loan Safe Harbor

TILA HPML appraisal Rule (Dodd-Frank 2014): Safe Harbor requirements not satisfied.

Buyer Comment (2019-09-23): XXXXXX Elects to waive this exception.

09/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

B

A

Non QM

Non QM

No

208358915

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided the LO Compensation Disclosure at time of application.

Buyer Comment (2019-09-23): XXXXXX Elects to waive this exception.

09/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

B

A

Non QM

Non QM

No

208358915

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Page 4 of the final CD reflects Assumption is allowed yet the Note does not include assumption verbiage.

Buyer Comment (2019-09-23): XXXXXX Elects to waive this exception.

09/23/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

B

A

Non QM

Non QM

Yes

208358915

XXXXXX

XXXXXX

Property

Property - Appraisal

Appraisal Reconciliation

Appraisal is required to be in name of Lender

-

Missing appraisal transfer letter from Broker to Lender.

Reviewer Comment (2019-09-26): Appraisal transfer letter provided. Buyer Comment (2019-09-25): See attached appraisal transfer letter

09/26/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

B

A

Non QM

Non QM

No

208358917

XXXXXX

XXXXXX

Credit

Asset

Asset Documentation

Guideline Issue: Insufficient asset documentation.

-

60 days not verified please provide an additional statement above and beyond the XXXX19-XXXX19 statement in file.

Reviewer Comment (2019-09-25): Statement is not required as not used for assets only to verify $25,000 deposit copy if the check is in the file. Reviewer Comment (2019-09-24): The most recent business bank statement acct XXXXXXis XXXXXX and most recent personal bank statement XXXXXX is XXXXXX and an activity printout with next available date of XXXXXX. There is a month gap between the business B/S and personal B/S, also a 3 day gap on the personal statements. We either need updated business B/S or an additional month of personal B/S. Buyer Comment (2019-09-24): The account is merely shown to reflect the $25,000 transfer per guidelines.  The assets are shown as seasoned via the XXXXXX.  An additional 30 days of seasoning or account statements would not be required for the personal account. Reviewer Comment (2019-09-23): Guidelines still require 60 days history of account to be used towards reserves. Exceptions remians. Buyer Comment (2019-09-20): It appears this account had a $25,000 transfer from a seasoned business account and the account is being used for reserves only.   If we just use the $25,000 seasoned funds for reserves and back out the unseasoned additional $7984.50 funds, we'd still have adequate reserves and funds to close.  See calculation.

09/25/2019

1

A

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

A

B

B

A

A

N/A

N/A

No

208358917

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Missing

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to consumer.

Buyer Comment (2019-09-17): XXXXXX has elected to waive this exception.

09/17/2019

2

B

XXXXXX

XXXXXX

Investment

Refinance - Rate/Term

C

B

C

A

B

B

A

A

N/A

N/A

No

208358919

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-09-30): XXXXXX has elected to waive this exception

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208358919

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail.

Third party verification of self-employment not provided.

Reviewer Comment (2019-10-03): Address on internet search matches W-2 for borrower. Buyer Comment (2019-10-02): Please see 1120 which reflects borrowers own a XXXX; The address on the 1120 would not be an issue as the borrower has a home office which is permitted Reviewer Comment (2019-10-01): Per internet search provided, business address dos not match K-1's or 1120S's, which is using home address. Buyer Comment (2019-10-01): Please see FNMA Self-Employment which allows internet search to confirm existence of business Reviewer Comment (2019-09-30): Provide business lic verifying business is active.

10/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208358919

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Employment - S-Corp Test

Ability-to-Repay (Dodd-Frank 2014): Unable to verify current S-Corp status using reasonably reliable third-party records.

Third party verification of self-employment not provided.

Reviewer Comment (2019-10-03): Address on internet search matches W-2 for borrower. Buyer Comment (2019-10-02): Please see 1120 which reflects borrowers own a XXXX; The address on the 1120 would not be an issue as the borrower has a home office which is permitted Reviewer Comment (2019-10-01): Per internet search provided, business address dos not match K-1's or 1120S's, which is using home address. Buyer Comment (2019-10-01): Please see FNMA Self-Employment which allows internet search to confirm existence of business Reviewer Comment (2019-09-30): Provide business lic verifying business is active. Buyer Comment (2019-09-30): Please see 3rd party verification

10/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208358919

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Third party verification of self-employment not provided.

Reviewer Comment (2019-10-03): Address on internet search matches W-2 for borrower. Reviewer Comment (2019-09-30): Provide business lic verifying business is active.

10/03/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208358919

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $845.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Second Appraisal Fee was added to the final CD without a valid change of circumstance.

Reviewer Comment (2019-10-01): AMC reviewed exception. Upon further review exception may be cleared. Buyer Comment (2019-09-30): Please see FINAL CD reflects cure of $845

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208358919

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Title - Loan Tie-In Fee.  Fee Amount of $250.00 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

The Loan Tie-in Fee, paid to a vendor on the provider list, was added to the CD issued on XXXX19 without a valid change of circumstance.

Reviewer Comment (2019-10-01): AMC reviewed exception. Upon further review exception may be cleared. Buyer Comment (2019-10-01): Please see CHECK LABEL, PCCD, LOE

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208358919

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

The final CD disclosed a tolerance cure of $845.00; calculated cure is $1,095.00.

Reviewer Comment (2019-10-01): Tolerance exceptions are addressed. Exception Cleared. Buyer Comment (2019-10-01): Cure provided for $845 appraisal fee Buyer Comment (2019-10-01): Please see PCCD, LOE, Check Label

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208358919

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Compliance Report not provided.

Reviewer Comment (2019-10-01): Compliance Report provided. Buyer Comment (2019-10-01): Please see COMPLIANCE REPORT

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208358919

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Second Appraisal Fee.  Fee Amount of $845.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208358920

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Buyer Comment (2019-09-20): XXXXXX has elected to waive this exception.

09/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208358920

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-20): XXXXXX has elected to waive this exception.

09/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208358920

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Initial Closing Disclosure Timing without Waiver

TILA-RESPA Integrated Disclosure: Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing.

Closing Disclosure not provided to Borrower(s) at least three (3) business days prior to closing. (Initial/XXXXXX)

Reviewer Comment (2019-09-24): AMC received XX03 CD received the same day. Exception Cleared. Buyer Comment (2019-09-20): Executed initial CD uploaded for review.

09/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

A

A

C

B

A

A

Non QM

Non QM

No

208358921

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Missing evidence borrower was provided the Anti Steering Disclosure at time of application.

Buyer Comment (2019-09-24): XXXXXX has elected to waive this exception.

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208358921

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Missing evidence borrower was provided the LO Compensation Disclosure at time of application.

Buyer Comment (2019-09-24): XXXXXX has elected to waive this exception.

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208358921

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Prepaid Property Tax Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose number of months for Property Tax under Prepaids.

Final CD does not reflect the number of months for property taxes in Section F Prepaids.

Buyer Comment (2019-09-24): XXXXXX has elected to waive this exception.

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208358922

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $519.00 exceeds tolerance of $505.00.  Sufficient or excess cure was provided to the borrower at Closing.

09/18/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Final CD evidences Cure

B

A

A

A

B

A

A

A

Non QM

Non QM

Yes

208358922

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Property Value

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed an Appraised Property Value that did not match the actual Property Value for the loan.

Final CD indicates value at $xxxxx. Appraisal and Desk Review indicate value at  $xxxxx

Reviewer Comment (2019-09-23): Letter of Explanation & Corrected Closing Disclosure provided.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

B

A

A

A

B

A

A

A

Non QM

Non QM

Yes

208358923

XXXXXX

XXXXXX

Credit

Income

Income Eligibility

Borrower does not have audited P&L and also does not have a BizMiner report so this does not qualify for the program.

Co-borrower started new job in XXXX which pays both base and commission income. Exception is to allow YTD earnings (8 months) which included commission income for qualifying vs program requirement a minimum history of 2 years commission income is recommended; however, commission income that has been received for 12-24 months may be considered acceptable income, as long as there are positive factors to reasonably offset the shorter income history per FNMA.

Borrower has been employed as XXXXXX for the past 2.98 years with 10 years in the same profession. Two open mortgages reporting 0x30 since inception. No late payments on credit report for the past 48 months last late dated XXXXXX. No public records. 22.15 months reserves > 8 months guideline minimum 709 representative FICO score > 660 guideline minimum - 49 points above guideline minimum

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-26): Client has elected to waive this exception bases on compensating factors.

09/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208358923

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Buyer Comment (2019-09-27): XXXXXX has elected to waive this exception.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208358923

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Closing date XX13 per final CD and consummation date per notary is XXXX19.

Buyer Comment (2019-09-27): XXXXXX has elected to waive this exception.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208358923

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

cash to close

Buyer Comment (2019-09-27): XXXXXX has elected to waive this exception.

09/27/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208358923

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXXX exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Missing valid or COC or evidence of cure for increase in Zero Percent Fees. Mortgage Broker Fee.

Reviewer Comment (2019-10-02): COC provided Buyer Comment (2019-10-01): The revised 9/4 LE is where the change occurred. There were no points charged on this revised LE. The LE is in your portal and uploaded here as well. Reviewer Comment (2019-09-30): AMC received COC however the total loan origination costs increased. Please provide detailed changed circumstance that indicates why the borrower requested a change in compensation. Typically, a borrower will not request of the lender to have their compensation changed from one to the other so we're looking to understand the circumstances behind the pricing change. We've gotten comfortable with accepting borrower requested change as a VCC when the change in compensation results in a benefit to the borrower in the form of lower overall origination charges being paid at closing. When the overall origination charges do not decrease with the change in compensation type, we will request additional information on the change Buyer Comment (2019-09-27): 9/4 Change of Circumstance which shows change from LPC to BPC uploaded.

10/02/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208358925

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Ten Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Ten Percent Fee Tolerance exceeded. Total amount of $175.00 exceeds tolerance of $146.00 plus 10% or $160.60.  Sufficient or excess cure was provided to the borrower at Closing.

09/23/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

B

A

A

A

A

Non QM

Non QM

Yes

208358925

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: PITIA reserves months discrepancy.

Calculated PITIA months reserves of ___ is less than Guideline PITIA months reserves of ___.

No public records.  Perfect credit history since inception of earliest account opened XXXXXX.  VOR reflects paid as agreed since inception XXXXXX DTI is 44.13996%, 5.86004% < program maximum of 50% Borrower has employment stability for 3 years as XXXXXX, in same line of work for the past 5 years. Credit score is 788, 148 points > program requirement of 640, LTV is 80%, 5% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-10-03): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-10-02): Please see REVISED APPROVED EXCEPTION Reviewer Comment (2019-09-26): Verified assets of $203,653.06. Final Closing Disclosure shows cash to close of $191,299.27 ($xxxx EMD + $181,299.27). Assets available for reserves of $12,353.79. Assets required to meet three months reserve requirement are $13,734.12. Buyer Comment (2019-09-25): Please see EXECUTED CD reflecting $181,299.27  CTC - assets $196,749.56 = $15,450.29 reserves / PITI4578.04 = 3.374 months reserves; only 3 months reserves are required

10/03/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

A

A

A

A

Non QM

Non QM

No

208358925

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender approved exception to allow co-borrower who only has one credit score reporting vs program guidelines that an application score for a borrower is the middle score for Borrowers with 3 valid credit scores, and  the lower score for Borrowers with 2 valid credit scores.

No public records.  Perfect credit history since inception of earliest account opened XXXXXX.  VOR reflects paid as agreed since inception XXXXXX DTI is 44.13996%, 5.86004% < program maximum of 50% Borrower has employment stability for 3 years as XXXXXX, in same line of work for the past 5 years. Credit score is 788, 148 points > program requirement of 640, LTV is 80%, 5% < program maximum of 85%

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-24): Client has elected to waive this exception based on compensating factors.

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

A

A

A

A

Non QM

Non QM

No

208358926

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-09-30): XXXXXX has elected to waive this exception.

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

A

B

B

A

A

Non QM

Non QM

No

208358926

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $849.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing.

Zero Percent Fee Tolerance exceeded for Appraisal Fee. Fee Amount of $849.00 exceeds tolerance of $650.00. Sufficient or excess cure was provided to the borrower at Closing

09/30/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

A

A

B

B

A

A

Non QM

Non QM

Yes

208358927

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

REO Documents are missing.

-

Statement not provided, unable to verify if tax/ins payments are included

Reviewer Comment (2019-09-27): Statement provided reflects taxes and ins included in payment. Buyer Comment (2019-09-26): February XX statement uploaded. Reviewer Comment (2019-09-17): Statement provided is dated XX. Provide a statement dated within 90 days of the note date. Buyer Comment (2019-09-16): Statement for XXXXXX uploaded.

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208358927

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

The broker fee disclosure was not provided.

Buyer Comment (2019-09-16): XXXXXX has elected to waive this exception.

09/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208358927

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

The Final CD has the closing date as XX.XX.XX and the borrower closed on XXXX.

Buyer Comment (2019-09-16): XXXXXX has elected to waive this exception.

09/16/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208358929

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

CPA letter or other documentation to provide percentage of ownership in business and shareholders % owned.

Reviewer Comment (2019-09-27): 1065 provided with % of ownership. Buyer Comment (2019-09-26): See the SSN it matches Flora is short for Florina Reviewer Comment (2019-09-26): Schedule B-1, Form 1065 provided shows Partners as XXXXX. Borrowers are XXXXX Buyer Comment (2019-09-25): Ownership for All Systems

09/27/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208358929

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

(State HPML Disclosure) Maryland Higher-Priced Mortgage Loan (Disclosure of Non-HPML Loans Borrower Qualifies For Not Provided)

XXXXXX Higher-Priced Mortgage Loan:  Borrower not provided with written disclosure of non-higher priced loans otherwise qualified for.

Buyer Comment (2019-09-25): XXXXXX has elected to waive this exception

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208358929

XXXXXX

XXXXXX

Compliance

Compliance

State Compliance

XXXXXX HPML Threshold Test Non-Compliant

XXXXXX Higher-Priced Mortgage Loan: APR on subject loan of 7.63280% or Final Disclosure APR of 7.72800% is in excess of allowable threshold of APOR 4.10% + 1.5%, or 5.60000%.  Non-Compliant Higher Priced Loan.

Buyer Comment (2019-09-25): XXXXXX has elected to waive this exception

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

A

B

B

A

A

Non QM

Non QM

No

208358929

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Survey Fee.  Fee Amount of $350.00 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower at Closing.

Cure provided on final CD of $350.00 exceeded amount of cure.  $350.00 cure required. Amount of credit given was $2429.81

09/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

C

B

C

A

B

B

A

A

Non QM

Non QM

Yes

208358930

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

The Hazard Insurance Policy effective date is after the Transaction Date.

Hazard Insurance Policy Effective Date ___, Transaction Date:  ___

Hazard Insurance Policy Effective Date XXXXXX, Transaction Date:  XXXXXX

CDAIR in file with inspection date of 09/23/2019 showing no damage. 102.38 months reserves > 3 months guideline minimum by 99.38 mon 39.360% DTI on this J8 documentation loan < 50% guideline max - 10.640% below program guideline maximum LTV is 80%, 5% < program maximum of 85%

Originator Originator Originator Originator

Reviewer Comment (2019-10-02): Client elects to waive the exception with verified compensation factors Buyer Comment (2019-10-01): Uploaded For Review: Exception for Effective Date of HOI after closing. No Claims Attestation. Disaster Report confirming no damage to subject. Reviewer Comment (2019-09-30): Effective date xxxx is after consummation date 8/XX19. Please provide a corrected HOI policy. Reviewer Comment (2019-09-30): No additional information provided in trailing docs. Buyer Comment (2019-09-27): This file does not include a HUD-1 to be certified. Transaction was as owner occupied. CD was included in original upload. Reviewer Comment (2019-09-13): Provide a certified copy of the Final Settlement Statement to confirm actual disbursement date.

10/02/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

A

A

A

Non QM

Non QM

No

208358930

XXXXXX

XXXXXX

Credit

Legal / Regulatory / Compliance

Title / Lien Defect

There is no dollar amount noted on the title policy.

Reviewer Comment (2019-09-16): AMC received a title policy addendum with coverage amount of $xxxx. Buyer Comment (2019-09-16): Uploaded-Title Supplement Reviewer Comment (2019-09-13): Title documents received XXXXXX are not for the subject property or borrower. Buyer Comment (2019-09-13): Uploaded For Review: Correct Title Reviewer Comment (2019-09-13): Documents sent on XXXXXX were not received. Please resubmit. Buyer Comment (2019-09-12): Uploaded For Review: Title Supplement

09/16/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

A

A

A

Non QM

Non QM

No

208358930

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-09-13): Appraisal acknowledgement dated XXXXXX provided.

09/13/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

B

A

A

A

Non QM

Non QM

No

208358931

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Insurance address does not match Note address.

The insurance city of XXXX does not match the city indicated on the note of XXXX.

Reviewer Comment (2019-08-30): Address AKA reflecting XXXXXX is an acceptable city. Buyer Comment (2019-08-30): PLease see AKA HOI reflecting XXXXXX is an acceptable city

08/30/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358931

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Minimum Loan Amount discrepancy.

Note loan amount of ___ is less than Guideline minimum loan amount of ___.

Lender acknowledged exception to all loan amount of $xxxxx vs program loan minimum of $100,000

29.13301% DTI on this Alt documentation loan < 50% guideline max - 20.86699% below program guideline maximum Re-established tradelines since discharge of Chapter 7 BK in XXXXXX Self employed for the past 18 years as the owner of XXXXXX Credit score is 721, 61 points > program requirement of 660 Reserves are 89.03 months, 86.03 months > program requirement of 3 months

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-27): Client has elected to waive this exception based on compensating factors.

08/27/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358931

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Invalid exception: Final Closing Disclosure date does not that actual date of consummation. Final CD indicates disbursement date of XXXX19. CA is a dry funding state. Not unusual to have doc signing and funding/disbursement on different dates.

Buyer Comment (2019-08-28): XXXXXX has elected to waive this exception

08/28/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

B

B

A

A

Non QM

Non QM

Yes

208358931

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Revised Loan Estimate Received Date >  Closing Disclosure Received Date

TILA-RESPA Integrated Disclosure: Revised Loan Estimate XXXXXX received on or after the date the Closing Disclosure 8/XXXX 12:00:00 AM was received.

Loan estimate XXXXXX,received on or after the date of the Closing Disclosure XXXXXX was received.  LE not signed by borrower as received.

Buyer Comment (2019-08-28): XXXXXX has elected to waive this exception

08/28/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

No Defined Cure

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358931

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception to allow owner of mortgage broker originating the subject loan.

29.13301% DTI on this Alt documentation loan < 50% guideline max - 20.86699% below program guideline maximum Re-established tradelines since discharge of Chapter 7 BK in XXXXXX Self employed for the past 18 years as the owner of XXXXXX Credit score is 721, 61 points > program requirement of 660 Reserves are 89.03 months, 86.03 months > program requirement of 3 months

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-27): Client has elected to waive this exception based on compensating factors.

08/27/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358931

XXXXXX

XXXXXX

Credit

Guideline

Guideline Issue

Minimum of 600 square feet of gross living area required per company guidelines.

Lender acknowledged exception to allow subject with xxxxx sq. ft. gross living area vs. program minimum requirement of 500 sq ft GLA

29.13301% DTI on this Alt documentation loan < 50% guideline max - 20.86699% below program guideline maximum Re-established tradelines since discharge of Chapter 7 BK in XXXXXX Self employed for the past 18 years as the owner of XXXXXX Credit score is 721, 61 points > program requirement of 660 Reserves are 89.03 months, 86.03 months > program requirement of 3 months

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-08-27): Client has elected to waive this exception based on compensating factors.

08/27/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358931

XXXXXX

XXXXXX

Credit

Income / Employment

Income Documentation

Income Docs Missing:

-

Missing CPA letter for ownership % as Incorporator's cert list two parties.

Reviewer Comment (2019-09-19): CPA letter provided. Buyer Comment (2019-09-18): Please see CPA letter reflecting borrower 50% ownership revised DTI using revised income results in DTI of 27.945%

09/19/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

B

B

A

A

Non QM

Non QM

No

208358932

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final CD reflects closing date as XXXX19 yet date of consummation is XXXX19.

Buyer Comment (2019-09-24): XXXXXX has elected to waive this exception.

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

B

B

A

B

B

B

A

A

Non QM

Non QM

Yes

208358932

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $670.00 exceeds tolerance of $495.00.  Sufficient or excess cure was provided to the borrower at Closing.

Initial LE reflected an Appraisal Fee of $495 yet the final CD shows a charge of $670.  Lender provided a credit of $175 to cure.

09/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Final CD evidences Cure

B

B

A

B

B

B

A

A

Non QM

Non QM

Yes

208358932

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Qualify borrower's income based on bank statements only (profit and loss is not available) vs program requirement of 12 months most recent bank statements plus most recent 12 month P&L prepared by a CPA, tax preparer or borrower's business accounting staff to be used to document income.

Perfect credit history with never a late payment, spanning 5 mortgage accounts, with an earliest account inception date of XXXXXX, and no public records. Borrower has been self-employed in XXXXXX for the past 4 years. DTI is 27%, 23% < program requirement of 50%. 185 months of reserves 172 months > than program requirement of 13 months. Credit Score is 773, 93 points > program requirement of 680.

Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-25): Client has elected to waive this exception based on compensating factors.

09/25/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

B

B

A

B

B

B

A

A

Non QM

Non QM

No

208358933

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Lender acknowledged exception in file: Subject property was listed for sale om XXXX19, which listing was cancelled on XXXX19 (1 month vs program requirement that the Subject Property has not been listed for sale during the three-month period preceding the Date of the Loan. Comp factor on exception for DTI is not valid, comp factor indicates DTI is at 42.279, actual is 46.482.

Overall month payment reduction of approximately $3,860. Two open mortgages reflect paid as agreed, perfect credit history since inception of earliest account opened XXXXXX, four closed mortgages reflect paid as agreed, and no public records Borrower has been self-employed for the past 11 years as XXXXXX Co-Borrower has been in the same line of business for the past 9 years DTI is 46.482%, 3.518% < program maximum of 50% Reserves are 19.08 months, 16.08 months > program requirement of 3 months Credit score is 696, 36 points > program requirement of 660 Borrower has been self-employed for the past 11 years as XXXXXX Co-borrower has been in the same line of work for the past 9 years. Credit score is 696, 36 points > program requirement of 660.  Two open mortgages reflect paid as agreed, perfect credit history since inception of earliest account opened XXXXX. Four closed mortgages reflect paid as agreed.  No public records. Reserves are 20 months, 17 months > program requirement of 3 months DTI is 42.279%, 7.721% < program maximum of 50%

Aggregator Aggregator Aggregator Aggregator Aggregator Aggregator Originator Originator Originator Originator

Reviewer Comment (2019-09-24): Client elects to waive the exception with verified compensating factors

09/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

C

B

C

B

C

A

A

A

Non QM

Non QM

No

208358933

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Without Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.   Cure provided on page 3 of final CD of $699.00 was insufficient. Total cure is $827.50 less cure provided at closing of $699.00 = remaining cure of $128.50    No evidence in file that remaining cure was provided to borrower.

Reviewer Comment (2019-09-17): Tolerance exceptions are addressed. Exception Cleared.

09/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

A

A

A

Non QM

Non QM

Yes

208358933

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,349.00 exceeds tolerance of $650.00.  Insufficient or no cure was provided to the borrower.

Appraisal fee increased from $650.00 to $1,349.00 without a valid change circumstance. Tolerance exceeded.  No evidence cure provided to borrower.

Reviewer Comment (2019-09-17): A cure is indicated on the final CD. Exception Cleared. Buyer Comment (2019-09-16): cure applied on final cd

09/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

A

A

A

Non QM

Non QM

Yes

208358933

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Transfer Tax.  Fee Amount of $XXXX exceeds tolerance of $1,010.00.  Insufficient or no cure was provided to the borrower.

Transfer Tax Fee increased from $xxxxx to $xxxxx without a valid change circumstance. Tolerance exceeded. No evidence in file that cure was provided to borrower.

Reviewer Comment (2019-09-17): AMC received COC. Exception Cleared.

09/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

A

A

A

Non QM

Non QM

Yes

208358933

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided At Closing

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $1,349.00 exceeds tolerance of $650.00.  Sufficient or excess cure was provided to the borrower at Closing.

09/17/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Debt Consolidation

Final CD evidences Cure

C

B

C

B

C

A

A

A

Non QM

Non QM

Yes

208358934

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Final disclosure reflects an increase in total costs exceeding the legal limit, insufficient cure provided at closing

Reviewer Comment (2019-09-19): Letter of Explanation & Corrected Closing Disclosure provided Reviewer Comment (2019-09-19): Letter of Explanation and Corrected CD received.  Cure check for $195 and Proof of delivery still required to cure. Buyer Comment (2019-09-17): Uploaded For Review-LOX-Label-Check-PCCD Buyer Comment (2019-09-17): Uploaded For Review-PCCD-LOX-Label

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208358934

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $XXXXX exceeds tolerance of $14,039.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Mortgage Broker Fee.  Fee Amount of $xxxxx exceeds tolerance of $xxxxx.  Missing proof of valid change, insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-09-17): COC - loan amount increase Buyer Comment (2019-09-16): Uploaded For Review: VCOC

09/17/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208358934

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $795.00 exceeds tolerance of $600.00.  Insufficient or no cure was provided to the borrower.

Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $795.00 exceeds tolerance of $600.00.  Missing proof of valid change, insufficient or no cure was provided to the borrower.

Reviewer Comment (2019-09-20): AMC received refund check. Exception Cured. Buyer Comment (2019-09-19): Uploaded For Review: Label & Check. Please note that the check is not a separate upload, it is attached to Label Reviewer Comment (2019-09-19): Letter of Explanation and Corrected CD received.  Cure check for $195 and Proof of delivery still required to cure. Buyer Comment (2019-09-17): Uploaded For Review-PCCD-LOX-Label

09/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208358934

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Appraisal Fee.  Fee Amount of $795.00 exceeds tolerance of $600.00.  Sufficient or excess cure was provided to the borrower.

Letter of Explanation and Corrected CD received.  Cure check for $195 and Proof of delivery still required to cure.

Reviewer Comment (2019-09-20): AMC received refund check. Exception Cured.

09/20/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

A

A

C

B

A

A

Non QM

Non QM

Yes

208358935

XXXXXX

XXXXXX

Credit

Credit

Miscellaneous

Credit Exception:

Borrower has 1 tradeline rated 99 months within 12 months of the credit date vs program requirement of at least 3 tradelines rated at minimum 12 months with 2 active within 12 months of the credit date (Note: xxxxx and housing disqualified as they are paid by the business)

Additional tradelines appear on borrowers credit report and are paid as agree but are paid by borrowers business.  No public records Borrower has employment stability for 8 years as XXXXXX Credit score is 771,131 points > program requirement of 640. LTV is 57.692%, 27.308% < program maximum of 85%

Originator Pre-Close Originator Originator Pre-Close Originator Pre-Close

Reviewer Comment (2019-09-06): Client has elected to waive this exception based on compensating factors.

09/06/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208358935

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - Anti-Steering Disclosure Not Provided:  Unable to determine Anti-Steering compliance/Safe Harbor

Loan Originator Compensation:  Anti-Steering - Unable to determine Safe Harbor due to Anti-Steering Disclosure not provided to borrower.

Buyer Comment (2019-09-09): waive

09/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

B

B

C

B

A

A

Non QM

Non QM

No

208358935

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Finance Charge

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Finance Charge that does not match the actual finance charge for the loan.

Per final Loan approval index used is 2.029% - located within the lookback.

Reviewer Comment (2019-09-30): Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, and Corrected CD provided. Reviewer Comment (2019-09-17): Under disclosure results from the lender using payments starting in payment 61 using the index plus margin rounded down to 5.25% rate which is below the floor rate of 5.26% provided on the promissory Note Reviewer Comment (2019-09-17): Lender using payments starting in payment 61 using the index plus margin rounded down to 5.25% rate which is below the floor rate of 5.26% provided on the promissory Note resulting in an under disclosure of TOP, Finance Charge, and TIP. Will need refund in the amount of under disclosure, LOE, PCCD, and proof of delivery within 60 days of discovery to cure. Reviewer Comment (2019-09-16): Please provide a copy of lender's amortization schedule for review to assist in identifying difference in calculations. Buyer Comment (2019-09-13): Please provide finance charge calculation. I am calculating $1,140,118.67 at a balance of $750,000 with an APR of 5.3% and an index of 2.029%. Reviewer Comment (2019-09-12): Calculated Finance Charge is $1,142,169.79 with index used by Lender of 2.029%, a difference of $2,051.12 from Lender's calculated FC of $1,140,118.67.  Provide a Corrected CD, Copy of refund check for the under-disclosed amount, letter of explanation and proof of delivery to cure. Buyer Comment (2019-09-12): lock reflects index of 2.029% which matches index lookback on 8/23 Reviewer Comment (2019-09-11): Loan tested with minimum available index in look-back period.  Unable to address the exception. Reviewer Comment (2019-09-10): AMC received a screen shot of index value available.  It does not indicate which index was used by the lender for the closing.  At consummation the index value was 1.95% (minimum of 1.93250% used for testing).  An underdisclosed amount of $2,051.12 remains to be cured.  A corrected CD, copy of refund check for under-disclosed amount, letter of explanation and proof of delivery is required to cure.

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed amount, Corrected CD, and Re-open Rescission if Applicable

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208358935

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Interest Percentage

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total Interest Percentage that does not match the actual total interest percentage for the loan.

Per final Loan approval index used is 2.029% - located within the lookback.

Buyer Comment (2019-09-26): waive Buyer Comment (2019-09-26): Please advise your calc for the TIP

09/26/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208358935

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Total Of Payments

TILA-RESPA Integrated Disclosure - Loan Calculations: Final Closing Disclosure provided on XXXXXX disclosed a Total of Payments that does not match the actual total of payments for the loan.

Per final Loan approval index used is 2.029% - located within the lookback.

Reviewer Comment (2019-09-30): Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, and Corrected CD provided. Buyer Comment (2019-09-26): uploaded pccd/refund Reviewer Comment (2019-09-17): Under disclosure results from the lender using payments starting in payment 61 using the index plus margin rounded down to 5.25% rate which is below the floor rate of 5.26% provided on the promissory Note Reviewer Comment (2019-09-11): Loan tested with minimum available index in look-back period.  Unable to address the exception. Reviewer Comment (2019-09-10): Minimum (1.93250%) index available during 45 day look back period used for testing.  TOP is under-disclosed by $2,051.12.  To cure a Corrected CD and LOE are required.  The calculated TOP is $1,894,193.79. Buyer Comment (2019-09-09): uploaded index lookback - 2.029% is within the 90 day lookback

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected CD, and Re-open Rescission if Applicable

C

B

B

B

C

B

A

A

Non QM

Non QM

Yes

208359887

XXXXXX

XXXXXX

Credit

Insurance

Insurance Analysis

Hazard Insurance policy does not list "Lender its successors and assigns", per guideline requirements.

Reviewer Comment (2019-10-03): Hazard Insurance policy list "Lender its successors and assigns", provided.

10/03/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation

ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-09-30): Corrected appraisal tab.

09/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Federal HPML 2014 Non Compliant

Federal Higher-Priced Mortgage Loan: APR on subject loan of 6.98580% or Final Disclosure APR of 7.00700% is in excess of allowable threshold of APOR 4.10% + 2.5%, or 6.60000%.  Non-Compliant Higher Priced Mortgage Loan.

Reviewer Comment (2019-09-30): Corrected appraisal tab. Buyer Comment (2019-09-30): uploaded appraisal delivery

09/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

(Fed HPML Provision) Federal Higher-Priced Mortgage Loan (Timing of Appraisal to Consumer)

TILA HPML Appraisal Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.

Reviewer Comment (2019-09-30): Corrected appraisal tab. Buyer Comment (2019-09-30): uploaded appraisal delivery

09/30/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Possible Federal Loan Originator Compensation - LO Comp Disclosure Not Provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Loan Originator Compensation (Dodd-Frank 2014) - Loan Originator Compensation disclosure not provided: Unable to determine from evidence in the loan file if compensation was based on a term of the transaction.

Buyer Comment (2019-09-30): waive

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Reviewer Comment (2019-10-01): Property taxes used are from the XX Certificate of current property tax status. This includes taxes for the Township, County and School.  Revised 1008 provided with correct taxes. Corrected DTI is 49.67476%. Reviewer Comment (2019-09-30): Updated DTI is 50.245% Buyer Comment (2019-09-30): uploaded appraisal delivery

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 51.34494% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Reviewer Comment (2019-10-01): Property taxes used are from the XX Certificate of current property tax status. This includes taxes for the Township, County and School.  Revised 1008 provided with correct taxes. Corrected DTI is 49.67476%. Reviewer Comment (2019-09-30): Updated DTI is 50.245% Buyer Comment (2019-09-30): DTI is 49.992%

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.  Closing date is XXXX19, Date of Disbursement on CD is XXXX19

Reviewer Comment (2019-10-01): Letter of Explanation & Corrected Closing Disclosure provided Buyer Comment (2019-09-30): uploaded PCCD

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Estimated Total Minimum Payment Adjustable Rate

TILA-RESPA Integrated Disclosure - Projected Payments: Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan.

Final Closing Disclosure provided on XXXXXX disclosed an Estimated Total Monthly Payment for payment stream 1 that does not match the actual total payment for the loan. School tax reflected on Tax Cert indicates annual bill of $9,600.37 or $800.03 monthly.  Final CD indicates monthly of 784.03 monthly

Reviewer Comment (2019-10-01): School taxes confirmed $9,408.36 due to Homestead rebate

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Corrected CD, and Re-open Rescission if Applicable

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Homeowner's Insurance Premium Months

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX disclosed homeowner's insurance under Prepaids that does not match amount per month calculation.

School tax reflected on Tax Cert indicates annual bill of $9,600.37 or $800.03 monthly.  Final CD indicates monthly of 784.03 monthly

Buyer Comment (2019-10-02): waive Reviewer Comment (2019-10-01): Letter of Explanation & Corrected Closing Disclosure required to cure.  Post Close CD received discloses 12 months of prepaid insurance in Section F. With $991.45 due at closing and a monthly premium of $84.67 that would equate to 11.71 months.  the number of months of prepaid insurance is not permitted to be rounded given that this disclosure is not specifically allowed to be rounded under the rule Buyer Comment (2019-09-30): uploaded PCCD

10/02/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Tax Reserves Other 1 Escrow

TILA-RESPA Integrated Disclosure - Other Costs: Final Closing Disclosure provided on XXXXXX did not disclose figures for Tax Reserves - Other under Initial Escrow Payment at Closing.

School tax reflected on Tax Cert indicates annual bill of $9,600.37 or $800.03 monthly.  Final CD indicates monthly of 784.03 monthly

Buyer Comment (2019-10-02): waive Reviewer Comment (2019-10-01): Letter of Explanation & Corrected Closing Disclosure required to cure.  Post Close CD received.  Section G page 2 does not disclose the # of months for Initial Escrow Payment for School Taxes Buyer Comment (2019-09-30): uploaded PCCD

10/02/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

A

C

B

A

A

Non QM

Non QM

Yes

208359887

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of 51.34494% exceeds Guideline total debt ratio of 50.00000%.

Reviewer Comment (2019-10-01): Property taxes used are from the Certificate of current property tax status. This includes taxes for the Township, County and School Revised 1008 provided with correct taxes. Corrected DTI is 49.67476%. Buyer Comment (2019-10-01): Please provide itemized monthly debt calculation Reviewer Comment (2019-09-30): Updated DTI is 50.245% Buyer Comment (2019-09-30): uploaded 1008. DTI is 49.992%

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Based on the loan failing one or more guideline components, the loan is at ATR risk. DTI > 50%

Reviewer Comment (2019-10-01): Property taxes used are from the XX Certificate of current property tax status. This includes taxes for the Township, County and School.  Revised 1008 provided with correct taxes. Corrected DTI is 49.67476%. Reviewer Comment (2019-09-30): Updated DTI is 50.245% Buyer Comment (2019-09-30): uploaded 1008. DTI is 49.992%

10/01/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208359887

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

ECOA Appraisal - Appraisal Provided Prior to Date Performed

ECOA Valuations Rule (Dodd-Frank 2014): Date valuation provided to applicant is prior to the date when valuation was performed.  Unable to determine compliance with appraisal timing requirements.

Buyer Comment (2019-09-30): waive

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

A

C

B

A

A

Non QM

Non QM

No

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

FACTA Disclosure Missing

FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.

FACTA disclosure delivery to borrower not located in file.

Reviewer Comment (2019-08-30): Waive per client request.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Loan allows for assumption per note in file.

Reviewer Comment (2019-08-30): Waive per client request.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure With Seller - Total Closing Costs Exceeds Limits

TILA-RESPA Integrated Disclosure - Calculating Cash to Close: Final Closing Disclosure provided on XXXXXX disclosed an inaccurate value of the dollar amount by which the Total Closing Costs exceeded the legal limit.

Cure for various 0% and 10% tolerance violations $48.60 was not provided.  Provide a post-close CD disclosing the tolerance cure of $48.60 copy the refund check, proof of delivery, and a copy of the letter of explanation sent to the borrower disclosing the changes made.

Reviewer Comment (2019-08-30): Waive per client request.

08/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Loan Estimate Seven Day Waiting Period

TILA-RESPA Integrated Disclosure: Loan Estimate was not delivered or placed in the mail to the borrower at least seven (7) business days prior to closing.

Loan Estimate dated XXXXXX was not received by the borrowers at least 4 business days prior to the closing date of XXXXXX. File does not contain evidence of earlier borrower receipt or a written and signed statement from the borrowers that waives the required waiting period.

Reviewer Comment (2019-10-22): Lender provided attestation to accept the borrowers request for a bona fide emergency for the delivery of the Initial LE. Reviewer Comment (2019-10-22): Regraded to EV2-B based on consumer's written hardship letter in the file and client's agreement that situation is a bona fide financial emergency. Reviewer Comment (2019-10-21): Waiver has been escalated for downgrade review. Buyer Comment (2019-10-15): Please see subsequent letter received from borrower Reviewer Comment (2019-10-14): Letter from the borrower is dated prior to receipt of application or LE.  In order for borrower to waive right, they need to receive disclosures  required by § 1026.18. Buyer Comment (2019-10-09): please see loe from borrower. needed to close early so lender accommodated to avoid them losing their earnest funds Reviewer Comment (2019-09-10): The LE was issued and signed by the borrower on XXXXXX.  The security instrument was notarized and Final CD signed on XXXXXX.  Loan Estimate was not delivered or placed in the mail to the borrower at least seven (7) business days prior to closing. Buyer Comment (2019-09-09): please see final ss attached.  closing date is X/X with disbursement 6/4

10/22/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

No Defined Cure

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Fee.  Fee Amount of $73.60 exceeds tolerance of $25.00.  Insufficient or no cure was provided to the borrower.

Appraisal Fee was disclosed as $25.00 on the Initial Loan Estimate dated XXXXXX, but disclosed as $73.60 on the Final Closing Disclosure. COC issued on XXXXXX disclosed the reason for the change as "broker credit report" however, the COC did not disclose what new information warranted the increase in the Credit Report Fee. Evidence of cure for the increase of $48.60 was not provided.

Reviewer Comment (2019-09-10): Cleared credit report fee was disclosed at $25 Buyer Comment (2019-09-09): please see uploaded fss. final credit report fee is 24.95.

09/10/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208405428

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Lender Exception(s) not provided

Borrower was qualified with bank statement income that was calculated using both business and personal bank statements which are not allowed per XXXXXX Bank Statement guidelines. File is missing a client approved exception with verified compensating factors related to the borrower's ability to repay to allow the co-mingling of personal and business bank accounts.

42.12% DTI on this Bank Statement documentation loan < 50.00% guideline max - 7.88% below program guideline maximum Borrower has residual income of $12,840.84

Originator Originator

Reviewer Comment (2019-09-19): Lender approved exception to allow the co-mingling of personal and business bank statements to verify the borrower's bank statement income.

09/19/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Bank Statements

Ability to Repay (Dodd-Frank 2014): Unable to verify Bank Statement income using reasonably reliable third-party records.

Borrower was qualified with bank statement income that was verified with a CPA Letter dated XXXXXX, a business entity filing dated XXXXXX, most recent bank statements (personal and business) dated XXXXXX and a P&L Statement dated through XXXX however, the subject loan closed on XXXXXX. All income documentation is expired per XXXXXX guidelines, which allows up to 90 days for expiration. Upon receipt of the more recent required income documentation, additional conditions may apply.

Reviewer Comment (2019-10-09): Received the personal and business bank statements dated XXXXXX. Buyer Comment (2019-10-08): please see march statements for personal and business attached Reviewer Comment (2019-09-19): Income documentation provided is expired after 90 days under ATR Rules and this exception cannot be waived.The following documents are required:   1) At a minimum, the March XX statements for both the personal and business accounts. 2) More recent business entity filing. Upon receipt of the above documentation, this exception will be retested under ATR.

10/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - Bank Statements

Ability to Repay (Dodd-Frank 2014): Unable to verify Bank Statement income using reasonably reliable third-party records.

Borrower was qualified with bank statement income that was verified with a CPA Letter dated XXXXXX, a business entity filing dated XXXXXX, most recent bank statements (personal and business) dated XXXXXX and a P&L Statement dated through XXXX however, the subject loan closed on XXXXXX. All income documentation is expired per XXXXXX guidelines, which allows up to 90 days for expiration. Upon receipt of the more recent required income documentation, additional conditions may apply.

Reviewer Comment (2019-10-09): Received the personal and business bank statements dated XXXXXX. Buyer Comment (2019-10-08): please see march bank statements uploaded Reviewer Comment (2019-09-19): Income documentation provided is expired after 90 days under ATR Rules and this exception cannot be waived.The following documents are required:   1) At a minimum, the March XX statements for both the personal and business accounts. 2) More recent business entity filing. Upon receipt of the above documentation, this exception will be retested under ATR. Buyer Comment (2019-09-05): Please see response under 'General Ability to Repay' tab.

10/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail.

Due to expired self-employed income and employment documentation, the subject loan designation is ATR Fail.

Reviewer Comment (2019-10-09): Received the personal and business bank statements dated XXXXXX. Buyer Comment (2019-10-08): please see march bank statements uploaded Reviewer Comment (2019-09-19): Income documentation provided is expired after 90 days under ATR Rules and this exception cannot be waived.The following documents are required:   1) At a minimum, the March XX statements for both the personal and business accounts. 2) More recent business entity filing. Upon receipt of the above documentation, this exception will be retested under ATR. Buyer Comment (2019-09-05): Please see response under 'General Ability to Repay' tab.

10/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Due to expired self-employed income and employment documentation, the subject loan designation is ATR Fail.

Reviewer Comment (2019-10-09): Received the personal and business bank statements dated XXXXXX.

10/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation Without Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Re-Issue Fee.  Fee Amount of $48.65 exceeds tolerance of $0.00.  Insufficient or no cure was provided to the borrower.

Added: Broker Credit report fee added on the Final CD.  COC in the file states credit report fee not know or disclosed on LE.  Loan is a broker loan and the broker credit report fee should have been know by the lender at the time the LE was issued.

Reviewer Comment (2019-10-09): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cleared.. Buyer Comment (2019-10-08): pccd and cure

10/09/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Fee Tolerance Refund Provide the Following: Letter of Explanation, Proof of Delivery, Copy of Refund Check, and Corrected CD

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208405428

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Zero Percent Tolerance Violation With Sufficient Cure Provided

TILA-RESPA Integrated Disclosure: Zero Percent Fee Tolerance exceeded for Credit Report Re-Issue Fee.  Fee Amount of $48.65 exceeds tolerance of $0.00.  Sufficient or excess cure was provided to the borrower.

Reviewer Comment (2019-10-09): AMC received PCCD indicating cure, LOE, and Refund Check. Exception Cured.

10/09/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208488771

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Verified information per the Final Closing Disclosure provided.

Reviewer Comment (2019-10-05): Waive per client request.

10/05/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208488771

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Non Escrowed Property Costs Year 1

TILA-RESPA Integrated Disclosure - Loan Disclosures: Amount of Non-Escrowed Property Costs over Year 1 of $5,124.00 on Final Closing Disclosure provided on XXXXXX not accurate.

Final Closing Disclosure disclosed Non-Escrowed Property Costs over Year 1 of $2,460.00. Non-Escrowed Property Costs are $200.00 per month, which equates to calculated Escrowed Property Costs over Year 1 of $2,400.00. Letter of Explanation to the borrower and Corrected Closing Disclosure are required to cure this exception.

Reviewer Comment (2019-10-09): AMC received PCCD correcting non escrowed property costs and LOE. Exception Cured. Buyer Comment (2019-10-08): pccd and delivery

10/09/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208488771

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Calculated investor qualifying total debt ratio of ___ exceeds Guideline total debt ratio of ___.

Per XXXXXX Income Calculation Analysis, the borrower was qualified with a DTI of 55.15% which exceeds the Full Doc guideline maximum DTI of 50.00%. Calculated DTI is 55.12%. Because the DTI exceeds the guideline maximum by more than 5%, this exception cannot be waived or compensated to a lower grade.

Housing payment history clean for 26 months Borrower has residual income of $9,690.52

Originator Originator

Reviewer Comment (2019-10-24): Lender approved exception to add asset depletion income using cash-out proceeds and a DTI exception up to 53.895%. Final DTI is 50.64%.

10/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208488771

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 55.12315% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Per XXXXXX Income Calculation Analysis, the borrower was qualified with a DTI of 55.15% which exceeds the Full Doc guideline maximum DTI of 50.00%. Calculated DTI is 55.12%. Because the DTI exceeds the guideline maximum by more than 5%, this exception cannot be waived or compensated to a lower grade.

Housing payment history clean for 26 months Borrower has residual income of $9,690.52

Originator Originator

Reviewer Comment (2019-10-24): Reran compliance. Reviewer Comment (2019-10-24): Lender approved exception to add asset depletion income using cash-out proceeds and a DTI exception up to 53.895%. Final DTI is 50.64%. Buyer Comment (2019-10-08): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208488771

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Due to a DTI of 55.12%, the subject loan is at ATR Risk. Because the DTI exceeds the guideline maximum by more than 5%, this exception cannot be waived or compensated to a lower grade.

Reviewer Comment (2019-10-24): Lender approved exception to add asset depletion income using cash-out proceeds and a DTI exception up to 53.895%. Final DTI is 50.64%. Buyer Comment (2019-10-08): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208488771

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to a DTI of 55.12%, the subject loan is at ATR Risk. Because the DTI exceeds the guideline maximum by more than 5%, this exception cannot be waived or compensated to a lower grade.

Reviewer Comment (2019-10-24): Lender approved exception to add asset depletion income using cash-out proceeds and a DTI exception up to 53.895%. Final DTI is 50.64%. Buyer Comment (2019-10-08): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/24/2019

1

A

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208488771

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both moderately exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 50.63803% moderately exceeds the guideline maximum of 50.00%. (DTI Exception is eligible to be regraded with compensating factors.)

Original XXXXXX income worksheet approved the borrower with a DTI of 55.15%. Lender approved exception to add asset depletion income using cash out proceeds.

Housing payment history clean for 26 months Borrower has residual income of $9,690.52

Originator Originator

Reviewer Comment (2019-10-24): Lender approved exception to add asset depletion income using cash-out proceeds and a DTI exception up to 53.895%. Final DTI is 50.64%.

10/24/2019

2

B

XXXXXX

XXXXXX

Primary

Refinance - Cash-out - Other

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208488773

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Closing Date

TILA-RESPA Integrated Disclosure - General Information: Final Closing Disclosure provided on XXXXXX disclosed a Closing Date that did not match the actual date of consummation.

Borrower signature date of XXXXXX does not match the CD issued date of XXXXXX.

Reviewer Comment (2019-09-30): Waive per client request.

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208488773

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Seller Closing Disclosure

TILA-RESPA Integrated Disclosure:  Seller Closing Disclosure not located in the file.

File is missing the Seller's Closing Disclosure.

Reviewer Comment (2019-09-30): Waive per client request.

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208488773

XXXXXX

XXXXXX

Credit

Loan Package Documentation

Application / Processing

Missing Document: Fraud Report not provided

File is missing the borrower's full Fraud Report.

Reviewer Comment (2019-10-08): Received Buyer Comment (2019-10-02): please see fraudgaurd

10/08/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208488773

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Section 11 of the Note indicates it is assumable; this does not reconcile with the final CD.

Reviewer Comment (2019-09-30): Waive per client request.

09/30/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208488773

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower was qualified with 24-months business bank statement income of $101,676.73 and a DTI of 19.29%. Per XXXXXX business bank statement guidelines, business bank statement income is calculated using the lower of the P&L 24-month average or the income disclosed on the signed Initial 1003. The P&L 24-month average is $101,676.75 however, the signed Initial 1003 disclosed $29,136.00 for the borrower's bank statement income. Using the lower required Initial 1003 income results in a DTI of 60.76%.

Housing payment history clean for 83 months 94.56 months reserves > 6 months guideline minimum 19.31% DTI on this Bank Statement documentation loan < 50.00% guideline max - 30.69% below program guideline maximum

Originator Originator Originator

Reviewer Comment (2019-10-24): Lender approved exception to allow the borrower to be qualified with the 24-month business bank statement average when the Initial 1003 disclosed a much lower income, which is required to be used by the guidelines. Final DTI is 19.31%.

10/24/2019

2

B

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208488773

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General ATR Provision Investor and Non QM DTIs match and both significantly exceed Guidelines

Ability to Repay (Dodd-Frank 2014): The DTI calculated in accordance with the Lenders Guidelines and 1026.43(c)(5) of 60.76369% significantly exceeds the guideline maximum of 50.00%. (DTI Exception requires compelling compensating factors to consider regrading to EV2-B.)

Borrower was qualified with 24-months business bank statement income of $101,676.73 and a DTI of 19.29%. Per XXXXXX business bank statement guidelines, business bank statement income is calculated using the lower of the P&L 24-month average or the income disclosed on the signed Initial 1003. The P&L 24-month average is $101,676.75 however, the signed Initial 1003 disclosed $29,136.00 for the borrower's bank statement income. Using the lower required Initial 1003 income results in a DTI of 60.76%.

Reviewer Comment (2019-10-24): Lender approved exception to allow the borrower to be qualified with the 24-month business bank statement average when the Initial 1003 disclosed a much lower income, which is required to be used by the guidelines. Final DTI is 19.31%. Buyer Comment (2019-10-02): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208488773

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR Risk

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Risk.

Due to the borrower's business bank statement income was not calculated in accordance with XXXXXX business bank statement guidelines and a DTI of 60.76%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-24): Lender approved exception to allow the borrower to be qualified with the 24-month business bank statement average when the Initial 1003 disclosed a much lower income, which is required to be used by the guidelines. Final DTI is 19.31%. Buyer Comment (2019-10-02): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

Lender to provide updated ATR/QM Loan Designation

C

B

C

B

C

B

A

A

Non QM

Non QM

Yes

208488773

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Due to the borrower's business bank statement income was not calculated in accordance with XXXXXX business bank statement guidelines and a DTI of 60.76%, the subject loan is at ATR Risk.

Reviewer Comment (2019-10-24): Lender approved exception to allow the borrower to be qualified with the 24-month business bank statement average when the Initial 1003 disclosed a much lower income, which is required to be used by the guidelines. Final DTI is 19.31%. Buyer Comment (2019-10-02): Please see "Investor qualifying total debt ratio discrepancy" tab for response.

10/24/2019

1

A

XXXXXX

XXXXXX

Primary

Purchase

C

B

C

B

C

B

A

A

Non QM

Non QM

No

208488774

XXXXXX

XXXXXX

Property

Property - Appraisal

Property Eligibility - Zoning and Usage

Valuation Issue: Subject use is illegal for zoning.

-

Appraisal #2 dated XXXXXX, reflects Zoning Compliance as Illegal and the appraiser did not comment on the illegal zoning or how this impacts the marketability of the subject property.

Reviewer Comment (2019-10-23): Received an updated primary which corrected the Zoning to Legal. Buyer Comment (2019-10-08): Updated appraisal attached. Buyer Comment (2019-10-03): The house was just built in XX, conforms to the neighborhood, and both appraisals state that the use is the highest and best use.   We did not ask for clarification from XXXXXX on zoning being indicated as illegal because it is clearly a typo.  The zoning is RE-24 which is SFR with minimum 24,000 sq ft site which the property meets.

10/23/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208488774

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

TRID Final Closing Disclosure Assumption

TILA-RESPA Integrated Disclosure - Loan Disclosures: Final Closing Disclosure provided on XXXXXX incorrectly disclosed whether the loan allows for Assumption.

Note provides verbiage loan is assumable .Closing Disclosure indicates loan is not assumable.

Reviewer Comment (2019-09-30): Waive per client request.

09/30/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

Letter of Explanation & Corrected Closing Disclosure

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208488774

XXXXXX

XXXXXX

Credit

Credit

AUS Discrepancy / Guidelines Discrepancy

Guideline Requirement: Investor qualifying total debt ratio discrepancy.

Borrower was qualified with 24-months business bank statement income from 4 different business accounts totaling $85,000.00 and a DTI of 37.75%. Per XXXXXX business bank statement guidelines, business bank statement income is calculated using the lower of the P&L 24-month average or the income disclosed on the signed Initial 1003. The signed Initial 1003 disclosed $0.00 for the borrower's bank statement income therefore, the qualifying income has been set to $0.00 and the DTI cannot be calculated.

39.00% DTI on this Bank Statement documentation loan < 50.00% guideline max - 11.00% below program guideline maximum Borrower has residual income of $50,175.69 29.84 months reserves > 14 months guideline minimum

Originator Originator Originator

Reviewer Comment (2019-10-23): Lender approved exception to allow the borrower to be qualified with the 24-month P&L averages for bank statement income for 4 separate companies when the guidelines require the lower of the P&L average or the income disclosed on the Initial 1003, which in this case was $0.00. Due to the loan not meeting the income guideline requirements, the lower bank statement averages were used and the final DTI is 39.00%.

10/23/2019

2

B

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208488774

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Income and Assets - No DTI Provided

Ability to Repay (Dodd-Frank 2014): No debt to income ratio (or a negative or zero ratio) was provided to demonstrate ability to repay.

Borrower was qualified with 24-months business bank statement income from 4 different business accounts totaling $85,000.00 and a DTI of 37.75%. Per XXXXXX business bank statement guidelines, business bank statement income is calculated using the lower of the P&L 24-month average or the income disclosed on the signed Initial 1003. The signed Initial 1003 disclosed $0.00 for the borrower's bank statement income therefore, the qualifying income has been set to $0.00 and the DTI cannot be calculated.

Reviewer Comment (2019-10-23): Lender approved exception to allow the borrower to be qualified with the 24-month P&L averages for bank statement income for 4 separate companies when the guidelines require the lower of the P&L average or the income disclosed on the Initial 1003, which in this case was $0.00. Due to the loan not meeting the income guideline requirements, the lower bank statement averages were used and the final DTI is 39.00%. Buyer Comment (2019-10-01): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

10/23/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208488774

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

General Ability To Repay Provision Investor Guidelines

Ability to Repay (Dodd-Frank 2014): Based on the loan failing one or more guideline components, the loan is at ATR risk.

Borrower was qualified with 24-months business bank statement income from 4 different business accounts totaling $85,000.00 and a DTI of 37.75%. Per XXXXXX business bank statement guidelines, business bank statement income is calculated using the lower of the P&L 24-month average or the income disclosed on the signed Initial 1003. The signed Initial 1003 disclosed $0.00 for the borrower's bank statement income therefore, the qualifying income has been set to $0.00 and the DTI cannot be calculated.

Reviewer Comment (2019-10-23): Lender approved exception to allow the borrower to be qualified with the 24-month P&L averages for bank statement income for 4 separate companies when the guidelines require the lower of the P&L average or the income disclosed on the Initial 1003, which in this case was $0.00. Due to the loan not meeting the income guideline requirements, the lower bank statement averages were used and the final DTI is 39.00%. Buyer Comment (2019-10-01): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

10/23/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

208488774

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

Check Loan Designation Match - ATR

Ability to Repay (Dodd-Frank 2014): Originator Loan Designation of Non QM does not match Due Diligence Loan Designation of ATR Fail.

Due to the borrower's business bank statement income was not calculated in accordance with XXXXXX business bank statement guidelines, the subject loan designation is ATR Fail.

Reviewer Comment (2019-10-23): Lender approved exception to allow the borrower to be qualified with the 24-month P&L averages for bank statement income for 4 separate companies when the guidelines require the lower of the P&L average or the income disclosed on the Initial 1003, which in this case was $0.00. Due to the loan not meeting the income guideline requirements, the lower bank statement averages were used and the final DTI is 39.00%. Buyer Comment (2019-10-01): Please see response under "Investor qualifying total debt ratio discrepancy" tab.

10/23/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

Lender to provide updated ATR/QM status

C

B

C

B

C

B

C

A

Non QM

Non QM

Yes

208488774

XXXXXX

XXXXXX

Compliance

Compliance

Federal Compliance

NonQM ATR

Ability-to-Repay (Dodd-Frank 2014): General Ability-to-Repay requirements not satisfied.

Due to the borrower's business bank statement income was not calculated in accordance with XXXXXX business bank statement guidelines, the subject loan designation is ATR Fail.

Reviewer Comment (2019-10-23): Lender approved exception to allow the borrower to be qualified with the 24-month P&L averages for bank statement income for 4 separate companies when the guidelines require the lower of the P&L average or the income disclosed on the Initial 1003, which in this case was $0.00. Due to the loan not meeting the income guideline requirements, the lower bank statement averages were used and the final DTI is 39.00%.

10/23/2019

1

A

XXXXXX

XXXXXX

Second Home

Purchase

C

B

C

B

C

B

C

A

Non QM

Non QM

No

EX-99.3

Exhibit 99.3 - Schedule 3

Valuation Report

Run Date - 10/31/2019 1:16:44 PM

LOAN INFORMATION

ORIGINATION VALUES

AVM VALUES

DESK REVIEW VALUES

BPO VALUES

FIELD REVIEW VALUES

2055 VALUES

UPDATED VALUES

UPDATED MULTIPROPERTY VALUES

AMC Loan ID

Customer Loan ID

Seller Loan ID

Note Date

Original Loan Amount

Sales Price

Appraised Value

Value for LTV

Appraisal Date

Second Appraisal Value

Variance Amount

Variance Percent

Second Appraisal Date

Second Appraisal Type

Appraised Value

Variance Amount

Variance Percent

Company

Confidence Score

Appraisal Date

Appraised Value

Variance Amount

Variance Percent

Company

Risk Score

Appraisal Date

Appraised Value

Variance Amount

Variance Percent

Company

Appraisal Date

Appraised Value

Variance Amount

Variance Percent

Company

Appraisal Date

Appraised Value

Variance Amount

Variance Percent

Company

Appraisal Date

Appraised Value

Variance Amount

Variance Percent

Company

Appraisal Date

Aggregate Appraised Value

Aggregate Variance Amount

Aggregate Variance Percent

Is Eligible for Rep and Warrant Relief per Loan Collateral Advisor?

Collateral Underwriter Risk Score

203612014

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/26/2017

Desk Review

XXXXXX

$0.00

Moderate

12/26/2017

203612092

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

03/09/2018

Desk Review

XXXXXX

$0.00

Low

03/09/2018

204989034

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.69%

11/05/2017

Appraisal

XXXXXX

$0.00

Low

10/30/2017

204989204

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2018

Desk Review

XXXXXX

$0.00

Low

07/10/2018

N/A

204989395

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

10/22/2018

Desk Review

XXXXXX

$0.00

Low

10/22/2018

N/A

204989408

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/25/2018

Desk Review

XXXXXX

$0.00

Low

07/25/2018

Yes

204989411

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

10/18/2018

Desk Review

XXXXXX

$0.00

Low

10/18/2018

No

204989508

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/14/2018

Desk Review

XXXXXX

$0.00

Moderate

05/14/2018

204991193

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/19/2018

Desk Review

XXXXXX

$0.00

Low

06/19/2018

N/A

204992231

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2018

Desk Review

XXXXXX

$0.00

Moderate

07/18/2018

N/A

206257472

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/25/2018

Desk Review

XXXXXX

$0.00

Low

07/25/2018

N/A

206257489

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/06/2018

Desk Review

XXXXXX

$0.00

Moderate

08/06/2018

N/A

206258001

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/12/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

11/12/2018

N/A

206258094

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/26/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

11/26/2018

N/A

206258100

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/22/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

11/22/2018

N/A

206315393

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

N/A

2.40

206337567

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

N/A

2.40

206889253

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

01/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

01/28/2019

N/A

206889256

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

01/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

01/14/2019

N/A

206889257

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/31/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

12/31/2018

N/A

206889259

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

01/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

01/25/2019

N/A

206889266

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/31/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

12/31/2018

N/A

206889272

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/02/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

12/02/2018

N/A

206889289

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

01/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

01/14/2019

N/A

206889301

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

02/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

02/13/2019

N/A

206889305

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/28/2018

AVM

XXXXXX

$0.00

UTD

11/28/2018

XXXXXX

XXXXXX

N/A

206889308

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.45%

03/11/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Low

03/09/2019

N/A

206889315

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

01/29/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

01/29/2019

N/A

206918662

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-2.33%

10/10/2018

AVM

XXXXXX

XXXXXX

-2.329%

XXXXXX

70

10/10/2018

XXXXXX

XXXXXX

N/A

206918680

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/25/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

12/25/2018

N/A

206918708

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/01/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

11/01/2018

N/A

206918715

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/05/2018

Desk Review

XXXXXX

$0.00

XXXXXX

12/05/2018

N/A

206918739

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

01/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

01/31/2019

N/A

206918744

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

01/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

01/27/2019

N/A

206945278

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/17/2019

N/A

206945951

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.58%

09/14/2018

Appraisal

XXXXXX

XXXXXX

N/A

206952469

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

02/05/2019

Appraisal

XXXXXX

XXXXXX

No

1.00

206964274

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

04/17/2019

N/A

206964302

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/19/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

04/22/2019

No

4.50

206964303

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-3.77%

04/12/2019

Desk Review

XXXXXX

XXXXXX

-3.774%

XXXXXX

Moderate

04/12/2019

N/A

206964315

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/22/2019

N/A

2.20

207100753

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

02/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

02/01/2019

N/A

207100761

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/23/2019

N/A

207107141

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/16/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/16/2019

N/A

207107145

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

4.17%

02/11/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

03/13/2019

N/A

207107161

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/22/2019

N/A

207107162

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/08/2019

N/A

207107164

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

04/30/2019

N/A

207139468

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/24/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

12/24/2018

N/A

207139472

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/16/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

11/16/2018

Yes

207194001

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/31/2019

N/A

207208647

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/19/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/19/2019

N/A

207208658

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/26/2019

N/A

207208664

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/31/2019

N/A

207208667

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

3.03%

04/29/2019

Appraisal

XXXXXX

XXXXXX

N/A

207358624

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/19/2019

Appraisal

XXXXXX

XXXXXX

N/A

207358625

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

N/A

2.00

207488014

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/17/2018

Field Review

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

12/17/2018

N/A

207488019

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/17/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

12/17/2018

N/A

207488020

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/11/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

12/11/2018

N/A

207488021

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-1.33%

12/07/2018

Desk Review

XXXXXX

XXXXXX

-1.333%

XXXXXX

Low

12/07/2018

N/A

207488022

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

10/29/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

10/29/2018

No

207488026

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

02/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

02/12/2019

N/A

207488027

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/22/2019

N/A

207488028

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-4.88%

01/30/2019

Desk Review

XXXXXX

XXXXXX

-4.878%

XXXXXX

Moderate

01/30/2019

N/A

207488030

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/09/2019

N/A

207488045

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/11/2019

XXXXXX

XXXXXX

XXXXXX

06/11/2019

N/A

207488048

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/06/2019

N/A

207488049

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/12/2019

N/A

207488050

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/20/2019

N/A

207488051

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/07/2019

N/A

207688253

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

10/10/2018

Desk Review

XXXXXX

$0.00

XXXXXX

High

10/10/2018

N/A

207688259

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

8.57%

12/02/2018

Appraisal

XXXXXX

XXXXXX

N/A

207688260

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/20/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

11/20/2018

N/A

207688261

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

10/25/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

10/25/2018

N/A

207688262

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/08/2018

Desk Review

XXXXXX

$0.00

XXXXXX

High

11/08/2018

N/A

207688264

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-5.71%

11/11/2018

Desk Review

XXXXXX

XXXXXX

-5.714%

XXXXXX

Moderate

11/11/2018

N/A

207688265

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/30/2018

Desk Review

XXXXXX

$0.00

XXXXXX

High

11/30/2018

N/A

207688266

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

11.49%

11/29/2018

Appraisal

XXXXXX

XXXXXX

N/A

207688267

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

01/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

01/02/2019

N/A

207688268

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/04/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

12/04/2018

N/A

207688269

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

02/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

02/12/2019

N/A

207688271

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.46%

11/12/2018

Appraisal

XXXXXX

XXXXXX

N/A

207688273

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

7.23%

10/01/2018

Appraisal

XXXXXX

XXXXXX

N/A

207688275

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.22%

12/21/2018

Appraisal

XXXXXX

XXXXXX

N/A

207688278

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/04/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

12/04/2018

N/A

207688280

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-1.04%

11/22/2018

Desk Review

XXXXXX

XXXXXX

-1.042%

XXXXXX

Moderate

11/22/2018

N/A

207688282

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/01/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

12/01/2018

N/A

207688283

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

10/10/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

10/10/2018

N/A

207688284

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-0.71%

11/28/2018

Appraisal

XXXXXX

XXXXXX

N/A

207688324

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

05/07/2019

N/A

207688325

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/09/2019

N/A

207688326

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

03/20/2019

Appraisal

XXXXXX

XXXXXX

N/A

207688327

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/14/2019

No

207688328

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-1.96%

05/06/2019

Desk Review

XXXXXX

XXXXXX

-1.961%

XXXXXX

Low

05/06/2019

No

207688329

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/06/2019

Appraisal

XXXXXX

XXXXXX

N/A

207688330

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

High

05/23/2019

N/A

207688345

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/22/2019

N/A

207764039

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-1.71%

05/05/2019

Appraisal

XXXXXX

XXXXXX

N/A

207764040

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/27/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

12/27/2018

N/A

207764041

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/20/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

12/20/2018

N/A

207764044

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.20%

08/23/2018

Appraisal

XXXXXX

XXXXXX

N/A

0.00

207787055

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/05/2019

N/A

207787067

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

04/30/2019

XXXXXX

XXXXXX

XXXXXX

04/30/2019

No

207787674

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/11/2019

N/A

207901869

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

06/02/2019

N/A

207901870

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/21/2019

N/A

207901871

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/09/2019

N/A

207901872

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/20/2019

N/A

207901873

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/23/2019

N/A

207901876

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/17/2019

N/A

207901877

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/17/2019

N/A

207901878

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/30/2019

N/A

207901888

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/11/2019

N/A

207901892

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/30/2019

No

207901893

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

3.57%

05/10/2019

Appraisal

XXXXXX

XXXXXX

No

207901956

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

2.10

207901957

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/10/2019

N/A

207901958

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/13/2019

N/A

207901959

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/12/2019

N/A

207901960

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/14/2019

N/A

207901961

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.86%

05/28/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

06/18/2019

N/A

207901962

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/20/2019

N/A

2.00

207901963

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/14/2019

N/A

207901964

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/23/2019

N/A

207901965

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/13/2019

No

2.40

207901966

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/04/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/04/2019

N/A

207901968

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

3.63%

06/11/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Low

06/11/2019

N/A

207901969

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/17/2019

N/A

3.70

207901970

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

207901972

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/15/2019

N/A

207901973

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/20/2019

N/A

4.50

207901974

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/03/2019

N/A

2.80

207901976

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/03/2019

N/A

207901977

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/09/2019

N/A

207901979

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/29/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/29/2019

N/A

5.00

207901980

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/13/2019

N/A

207901981

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

04/25/2019

N/A

207901982

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

04/15/2019

N/A

207901983

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/07/2019

N/A

207901984

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/03/2019

N/A

2.00

207901985

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/17/2019

N/A

207901986

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/24/2019

N/A

207901987

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/14/2019

N/A

4.40

207901988

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

04/24/2019

N/A

207901989

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/15/2019

N/A

2.80

207901990

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/26/2019

N/A

207901991

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

04/03/2019

N/A

207901992

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/10/2019

N/A

2.90

207901993

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/12/2019

No

207901994

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.33%

05/07/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

06/11/2019

N/A

207901995

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/14/2019

N/A

2.20

207901996

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/14/2019

N/A

207901997

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/22/2019

N/A

207901998

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/18/2019

N/A

207902000

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.92%

05/15/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Low

05/22/2019

N/A

207902001

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/16/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/16/2019

N/A

207902002

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

207902003

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/05/2019

N/A

4.00

207902004

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/17/2019

N/A

207902005

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/27/2019

N/A

207902006

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/21/2019

No

2.00

207902008

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/13/2019

N/A

207902009

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/25/2019

N/A

207902010

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/03/2019

N/A

207902011

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/07/2019

N/A

207902012

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

2.22%

05/19/2019

Desk Review

XXXXXX

XXXXXX

2.222%

XXXXXX

Moderate

05/19/2019

N/A

2.00

207902013

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/18/2019

N/A

207902014

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

04/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

04/24/2019

N/A

4.50

207902015

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/11/2019

N/A

207902016

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/25/2019

N/A

207902017

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/30/2019

N/A

207902018

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/26/2019

N/A

4.00

207902019

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

2.80

207902020

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/30/2019

No

207902021

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/14/2019

No

2.00

207902023

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/26/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

07/02/2019

N/A

1.50

207902024

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/20/2019

N/A

2.00

207902025

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/04/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/04/2019

N/A

1.70

207902026

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/26/2019

N/A

207902027

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/06/2019

N/A

207902028

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/17/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

207902029

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/05/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

06/26/2019

N/A

1.50

207902030

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/22/2019

N/A

207902031

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/28/2019

N/A

207902032

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-5.21%

05/22/2019

Desk Review

XXXXXX

XXXXXX

-5.213%

XXXXXX

Moderate

05/22/2019

N/A

2.40

207902033

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/17/2019

N/A

207902034

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/24/2019

No

5.00

207902035

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

3.03%

07/02/2019

Desk Review

XXXXXX

XXXXXX

3.030%

XXXXXX

Moderate

07/02/2019

N/A

207902036

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/25/2019

N/A

207902037

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/26/2019

No

2.20

207902038

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/02/2019

N/A

207902039

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/05/2019

N/A

207902040

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/28/2019

N/A

2.80

207902041

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/21/2019

N/A

207902042

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.03%

07/03/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

07/08/2019

N/A

4.30

207902043

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/10/2019

N/A

207902044

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/21/2019

No

207902045

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/27/2019

N/A

999.00

207902046

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/26/2019

N/A

207902047

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/28/2019

N/A

2.50

207902048

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/01/2019

No

2.00

207902049

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/10/2019

No

1.30

207902050

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/06/2019

N/A

207902051

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/27/2019

N/A

2.00

207902052

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/05/2019

N/A

207902055

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/15/2019

N/A

207902056

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/09/2019

N/A

207902057

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/21/2019

N/A

207902058

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/05/2019

N/A

207902059

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

34.48%

04/17/2019

Appraisal

XXXXXX

$0.00

XXXXXX

05/28/2019

N/A

207902060

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/09/2019

N/A

2.30

207902061

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/10/2019

N/A

207902062

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/10/2019

N/A

207902063

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

207902065

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/23/2019

N/A

207902066

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/03/2019

N/A

207902067

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/09/2019

N/A

207902068

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/14/2019

N/A

2.20

207902069

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/27/2019

N/A

4.60

207902070

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

5.26%

07/17/2019

Appraisal

XXXXXX

XXXXXX

5.263%

XXXXXX

Moderate

06/13/2019

N/A

2.20

207902071

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/10/2019

N/A

207902072

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/11/2019

N/A

207902075

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-1.64%

07/11/2019

Desk Review

XXXXXX

XXXXXX

-1.639%

XXXXXX

Low

07/11/2019

N/A

207902076

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/15/2019

N/A

207902077

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/30/2019

N/A

3.10

207902078

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/10/2019

N/A

207902079

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/03/2019

N/A

207902080

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

03/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

03/28/2019

N/A

207902081

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.72%

06/20/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

06/26/2019

N/A

2.10

207902082

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/09/2019

N/A

3.70

207902083

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/20/2019

N/A

207902084

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/11/2019

N/A

3.00

207902085

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/08/2019

N/A

207902086

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/28/2019

N/A

3.10

207902087

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/16/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/16/2019

XXXXXX

XXXXXX

XXXXXX

07/16/2019

N/A

207902088

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/18/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

06/11/2019

N/A

207902089

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/10/2019

N/A

207902090

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/27/2019

N/A

207902091

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/15/2019

N/A

2.40

207902092

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/08/2019

No

3.30

207902093

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/03/2019

N/A

207902094

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/12/2019

N/A

207902095

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/01/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

07/10/2019

N/A

1.20

207902096

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/18/2019

N/A

3.00

207902097

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-2.04%

07/09/2019

Desk Review

XXXXXX

XXXXXX

-2.037%

XXXXXX

Moderate

07/09/2019

N/A

2.40

207902098

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

26.00%

04/02/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

05/14/2019

N/A

207902099

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/29/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/29/2019

N/A

207902100

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/23/2019

N/A

207902103

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/18/2019

N/A

207902104

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/18/2019

N/A

4.00

207902105

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/11/2019

N/A

207902106

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/17/2019

N/A

207902107

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/02/2019

N/A

207902108

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/25/2019

N/A

2.10

207902110

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/24/2019

N/A

207902111

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/06/2019

N/A

207902112

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/19/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/19/2019

N/A

207902113

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/28/2019

Yes

3.90

207902114

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/30/2019

N/A

207902117

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/05/2019

N/A

4.00

207902118

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/03/2019

N/A

207902119

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/30/2019

N/A

207902120

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/19/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/19/2019

N/A

1.50

207902121

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/09/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Low

07/03/2019

N/A

3.30

207902122

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/19/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/19/2019

N/A

207902123

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/21/2019

N/A

207902124

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/08/2019

No

207902125

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/18/2019

N/A

207902126

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/20/2019

N/A

207902127

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/21/2019

N/A

207902128

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/18/2019

N/A

207902129

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/18/2019

N/A

207902130

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/25/2019

N/A

207902131

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/02/2019

N/A

207902132

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/22/2019

N/A

207902133

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/03/2019

N/A

207902134

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/20/2019

N/A

207902135

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

N/A

2.30

207902137

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/29/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/29/2019

N/A

207902138

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/09/2019

N/A

3.90

207902139

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/17/2019

N/A

207902140

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/01/2019

N/A

207902141

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/24/2019

N/A

2.20

207902142

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/31/2019

N/A

207902143

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-2.72%

07/29/2019

Desk Review

XXXXXX

XXXXXX

-2.719%

XXXXXX

Moderate

07/29/2019

N/A

207902144

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/30/2019

N/A

207902145

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/08/2019

N/A

207902146

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/25/2019

N/A

207902147

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/25/2019

N/A

207902148

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/22/2019

N/A

2.10

207902150

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.85%

08/06/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

05/03/2019

N/A

207902151

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/03/2019

N/A

207902152

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.85%

07/11/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

07/18/2019

XXXXXX

XXXXXX

XXXXXX

07/11/2019

N/A

207902153

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/18/2019

Yes

1.20

207902154

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/30/2019

N/A

207902155

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/30/2019

N/A

207902156

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/29/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/29/2019

N/A

1.00

207902157

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/01/2019

N/A

207902158

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/28/2019

N/A

207902159

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/03/2019

N/A

207902160

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/27/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Low

07/01/2019

N/A

207902161

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/23/2019

N/A

207902162

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/18/2019

N/A

207902163

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/06/2019

N/A

207902164

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/26/2019

N/A

3.30

207902165

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/26/2019

N/A

2.10

207902166

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/15/2019

N/A

207902167

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/23/2019

N/A

207902168

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/03/2019

N/A

207902169

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/02/2019

N/A

4.60

207902170

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/06/2019

N/A

2.20

207902171

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/31/2019

N/A

207902172

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/11/2019

N/A

207902173

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/06/2019

N/A

2.30

207902174

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/25/2019

N/A

207902175

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/30/2019

N/A

207902176

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/05/2019

N/A

207902177

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/20/2019

N/A

207902178

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/17/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

07/29/2019

N/A

207902179

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/06/2019

N/A

207902180

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/25/2019

N/A

207902181

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/07/2019

N/A

999.00

207902182

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/31/2019

N/A

999.00

207902183

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/06/2019

N/A

2.10

207902184

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/10/2019

N/A

207902185

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/31/2019

N/A

207902186

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.46%

07/31/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

08/06/2019

N/A

207902187

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/12/2019

N/A

2.50

207902188

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

8.33%

08/07/2019

Desk Review

XXXXXX

XXXXXX

8.333%

XXXXXX

Moderate

08/07/2019

N/A

207902189

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/18/2019

N/A

207902190

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/09/2019

N/A

2.00

207902191

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/21/2019

N/A

207902193

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/31/2019

N/A

207902194

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/01/2019

N/A

207902195

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.36%

07/20/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

07/30/2019

N/A

207902196

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/11/2019

N/A

207902197

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-3.72%

08/14/2019

Appraisal

XXXXXX

XXXXXX

-3.719%

XXXXXX

Moderate

08/13/2019

N/A

207902198

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/24/2019

N/A

207902199

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/16/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/16/2019

N/A

3.00

207902200

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-7.22%

08/19/2019

Desk Review

XXXXXX

XXXXXX

-7.217%

XXXXXX

Moderate

08/19/2019

N/A

207902201

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

4.76%

07/09/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

07/23/2019

N/A

207902202

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/01/2019

N/A

207902203

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/16/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/16/2019

N/A

4.00

207911186

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/12/2019

N/A

207911187

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/30/2019

Appraisal

XXXXXX

XXXXXX

N/A

207911188

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/27/2019

N/A

207911189

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/13/2019

N/A

207911191

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/12/2019

N/A

207911192

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/09/2019

N/A

207911194

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/30/2019

N/A

207911196

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/07/2019

N/A

207911202

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/05/2019

N/A

207911203

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.29%

04/30/2019

Appraisal

XXXXXX

XXXXXX

N/A

207911207

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/31/2019

N/A

207911208

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-2.17%

05/08/2019

Appraisal

XXXXXX

XXXXXX

N/A

207911209

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Appraisal

XXXXXX

XXXXXX

N/A

207911249

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/11/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

12/11/2018

N/A

207944361

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/30/2019

N/A

207944362

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/20/2019

N/A

207944364

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/10/2019

N/A

207944365

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.19%

06/05/2019

Appraisal

XXXXXX

XXXXXX

N/A

207944367

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

02/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

02/14/2019

N/A

208014771

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.00%

11/23/2018

Appraisal

XXXXXX

XXXXXX

N/A

2.00

208016566

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.91%

06/05/2019

Desk Review

XXXXXX

XXXXXX

0.909%

XXXXXX

Moderate

06/05/2019

N/A

208016567

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

09/24/2019

Desk-Top Review

XXXXXX

XXXXXX

-100.000%

XXXXXX

Indeterminate

06/10/2019

XXXXXX

$0.00

XXXXXX

09/24/2019

N/A

208016568

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/07/2019

N/A

208016569

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/05/2019

N/A

208016570

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

06/13/2019

N/A

208016571

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

208016572

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/22/2019

N/A

208016573

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/08/2019

N/A

208016574

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

05/31/2019

N/A

208016575

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/28/2019

Appraisal

XXXXXX

XXXXXX

N/A

208016576

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

12/13/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

12/13/2018

N/A

208016648

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/08/2019

N/A

208016649

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/19/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/19/2019

N/A

208016650

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/08/2019

N/A

2.40

208016651

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/01/2019

N/A

208016652

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/11/2019

N/A

208016653

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/02/2019

N/A

2.10

208016654

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

3.57%

07/04/2019

Desk Review

XXXXXX

XXXXXX

3.571%

XXXXXX

Moderate

07/04/2019

N/A

208016655

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/15/2019

N/A

208016656

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/12/2019

N/A

2.20

208016657

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/17/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/17/2019

N/A

208016658

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/18/2019

N/A

208016659

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/12/2019

N/A

208016660

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/15/2019

N/A

208016661

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/31/2019

N/A

208016662

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-5.45%

08/22/2019

Desk Review

XXXXXX

XXXXXX

-5.455%

XXXXXX

Moderate

08/22/2019

N/A

208016664

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/16/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/16/2019

N/A

2.00

208016665

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/12/2019

N/A

4.60

208016666

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/26/2019

N/A

208016667

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/30/2019

N/A

2.50

208016668

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/19/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/19/2019

N/A

208016669

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/14/2019

N/A

208016670

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/15/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/15/2019

N/A

208016671

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

3.13%

07/23/2019

Desk Review

XXXXXX

XXXXXX

3.125%

XXXXXX

Moderate

07/23/2019

N/A

208016672

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/06/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/06/2019

N/A

3.30

208016673

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/02/2019

N/A

208016674

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/11/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/11/2019

N/A

208016675

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/23/2019

N/A

208016676

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/14/2019

No

208016677

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/22/2019

N/A

208016678

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/01/2019

N/A

208016679

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/29/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/29/2019

N/A

208016680

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/25/2019

Desk Review

XXXXXX

$0.00

XXXXXX

07/25/2019

N/A

208016681

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/31/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/31/2019

N/A

208016682

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/09/2019

N/A

208016683

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/27/2019

N/A

208016684

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/16/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/16/2019

N/A

2.00

208016685

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/22/2019

N/A

1.30

208016686

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/28/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/28/2019

N/A

208016687

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/12/2019

N/A

208311491

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/12/2019

Desk Review

XXXXXX

$0.00

XXXXXX

06/12/2019

N/A

208311494

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/09/2019

N/A

208311495

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-8.43%

06/05/2019

Desk Review

XXXXXX

XXXXXX

-8.429%

XXXXXX

Moderate

06/05/2019

N/A

208311496

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/03/2019

N/A

208311497

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/10/2019

N/A

208311498

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.43%

06/04/2019

Desk Review

XXXXXX

XXXXXX

1.429%

XXXXXX

Low

06/04/2019

N/A

208311499

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/07/2019

N/A

208311500

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/12/2019

Appraisal

XXXXXX

XXXXXX

N/A

208311501

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/18/2019

N/A

208311502

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/07/2019

N/A

208311503

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/07/2019

N/A

208311504

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/22/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/22/2019

N/A

208311505

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/08/2019

N/A

208311506

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/20/2019

N/A

208311507

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/13/2019

N/A

208311508

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/18/2019

N/A

208311509

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.60%

06/14/2019

Desk Review

XXXXXX

XXXXXX

0.595%

XXXXXX

Moderate

06/14/2019

N/A

208311510

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/29/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/29/2019

N/A

208311511

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/14/2019

N/A

208311530

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/24/2019

Appraisal

XXXXXX

XXXXXX

N/A

208311538

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

208311540

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/13/2019

N/A

208311541

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/01/2019

N/A

208311542

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/10/2019

N/A

208311543

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/18/2019

N/A

208311544

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/27/2019

N/A

208311546

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/30/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/30/2019

N/A

208311547

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/21/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/21/2019

N/A

208311548

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/24/2019

N/A

208311551

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/01/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/01/2019

N/A

208311553

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/23/2019

N/A

208311556

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/14/2019

N/A

208311558

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

05/20/2019

N/A

208311559

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/27/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

06/27/2019

N/A

208311560

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/10/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/10/2019

N/A

208311561

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/13/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Low

11/13/2018

N/A

208311563

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

11/13/2018

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

11/13/2018

N/A

208323422

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

5.17%

06/26/2019

Appraisal

XXXXXX

N/A

208338379

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

5.77%

06/03/2019

Appraisal

XXXXXX

N/A

208358908

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/26/2019

N/A

2.50

208358909

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/26/2019

N/A

2.80

208358910

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/29/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/29/2019

N/A

208358911

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

22.73%

07/29/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

07/31/2019

N/A

208358912

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-8.33%

08/23/2019

Desk Review

XXXXXX

XXXXXX

-8.333%

XXXXXX

Moderate

08/23/2019

N/A

2.60

208358914

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/20/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/20/2019

N/A

208358915

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/18/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

07/18/2019

N/A

1.00

208358917

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/13/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/13/2019

No

208358918

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-0.04%

09/09/2019

Desk Review

XXXXXX

XXXXXX

-0.041%

XXXXXX

Moderate

09/09/2019

N/A

208358919

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

1.69%

09/09/2019

Appraisal

XXXXXX

XXXXXX

1.695%

XXXXXX

Low

09/12/2019

N/A

208358920

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-2.65%

08/23/2019

Desk Review

XXXXXX

XXXXXX

-2.655%

XXXXXX

Moderate

08/23/2019

N/A

208358921

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/05/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/05/2019

N/A

208358922

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/02/2019

N/A

208358923

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/23/2019

N/A

2.30

208358925

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/07/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/07/2019

N/A

2.10

208358926

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/26/2019

N/A

208358927

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/08/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/08/2019

N/A

208358929

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

0.93%

08/15/2019

Appraisal

XXXXXX

$0.00

XXXXXX

Moderate

09/02/2019

N/A

208358930

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-0.94%

08/23/2019

Desk Review

XXXXXX

XXXXXX

-0.943%

XXXXXX

Moderate

08/23/2019

N/A

1.90

208358931

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/03/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/03/2019

N/A

208358932

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/14/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

08/14/2019

N/A

208358933

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

07/24/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

07/24/2019

N/A

208358934

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

08/26/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

08/26/2019

N/A

208358935

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/23/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

06/23/2019

N/A

208359887

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

09/02/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Moderate

09/02/2019

N/A

208405428

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

05/09/2019

Desk Review

XXXXXX

$0.00

XXXXXX

Low

05/09/2019

N/A

208488771

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

$0.00

06/14/2019

Desk Review

$0.00

XXXXXX

Low

06/14/2019

N/A

208488773

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

-4.82%

08/05/2019

Desk Review

XXXXXX

XXXXXX

-4.819%

XXXXXX

08/05/2019

No

208488774

XXXX

XXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

XXXXXX

2.63%

06/07/2019

Appraisal

N/A

EX-99.3

Exhibit 99.3 - Schedule 4

Data Compare Summary (Total)
Run Date - 10/31/2019 1:16:50 PM
Field Label	Loans With Discrepancy	Total Times Compared	% Variance	# Of Loans
# of Borrowers	0	1	0.00%	482
# of Units	0	40	0.00%	482
Amortization Term	1	17	5.88%	482
Amortization Type	1	7	14.29%	482
Appraisal Date	6	16	37.50%	482
Appraised Value	0	1	0.00%	482
Balloon Flag	0	16	0.00%	482
Borrower First Name	1	22	4.55%	482
Borrower Last Name	0	32	0.00%	482
Borrower Qualifying FICO	0	1	0.00%	482
Borrower Self-Employed?	2	16	12.50%	482
Borrower SSN	0	16	0.00%	482
City	0	49	0.00%	482
Coborrower First Name	0	6	0.00%	482
Coborrower Last Name	0	6	0.00%	482
Coborrower Self-Employed?	2	16	12.50%	482
Coborrower SSN	0	6	0.00%	482
Contract Sales Price	2	37	5.41%	482
Doc Type	14	41	34.15%	482
First Payment Date	0	17	0.00%	482
Index Type	0	1	0.00%	482
Interest Only	0	16	0.00%	482
Interest Only Period	0	2	0.00%	482
Interest Rate Life Max	0	1	0.00%	482
Interest Rate Life Min	0	1	0.00%	482
Investor: Qualifying Total Debt Ratio	8	23	34.78%	482
Lien Position	0	23	0.00%	482
Lookback Period	0	1	0.00%	482
LTV Valuation Value	1	40	2.50%	482
Margin	4	19	21.05%	482
Maturity Date	0	16	0.00%	482
MERS Min Number	4	16	25.00%	482
Note Date	0	1	0.00%	482
Occupancy	1	49	2.04%	482
Original CLTV	0	23	0.00%	482
Original Interest Rate	0	41	0.00%	482
Original Loan Amount	0	49	0.00%	482
Original LTV	0	41	0.00%	482
Original P&I	0	16	0.00%	482
Original Term	7	41	17.07%	482
Origination Channel	0	1	0.00%	482
Origination Company Name	3	16	18.75%	482
Other Financing - Lien Position 2 - Original Loan Amount	0	1	0.00%	482
Property Type	8	41	19.51%	482
Purpose	0	49	0.00%	482
Refi Purpose	4	10	40.00%	482
Representative FICO	7	40	17.50%	482
Rounding Factor	0	1	0.00%	482
Secondary Appraisal Date	5	16	31.25%	482
Secondary Appraised Value	1	3	33.33%	482
State	0	49	0.00%	482
Street	1	30	3.33%	482
Total Cash-out	0	1	0.00%	482
Zip	0	31	0.00%	482
Total	83	1,072	0.00%	482

EX-99.4

Exhibit 99.4

Opus CMC Privileged and Confidential Page 1

Executive Narrative

October 31, 2019

Performed by

Opus Capital Markets Consultants, LLC

For

Neuberger Berman Investment Advisors LLC

This report summarizes the results of a due diligence review performed on a pool of 9 loans purchased by Neuberger Berman Investment Advisors LLC (“Customer”) from a client of Opus Capital Markets Consultants, LLC (“Consultant”). Consultant performed a detailed compliance and credit review on all loans and the diligence results were provided to the Customer under the terms of a reliance letter.

Consultant was established in 2005. Consultant was acquired in January 2014 by Wipro Ltd, a global information technology, consulting, and outsourcing company.

Credit Qualification: A re-underwriting review was conducted in order to verify that the requisite underwriting guidelines as specified by the Client were met. Confirmation of the loan terms were performed through recalculation and review of documentation contained in the loan file provided to the Consultant. The Credit Qualification review consisted of the following:

ü Guidelines: Determine whether each mortgage loan met the requisite guideline requirements as specified by the Client. In addition to the Client provided underwriting guides, Consultant considered Regulation Z including Appendix Q when applicable. If the loan pre-dated the requirements of Regulation Z and Appendix Q, Consultant considered Fannie Mae’s Seller guidelines;

ü Employment: Reviewed the file to determine employment was documented and verified to comply with the underwriting guides provided by the Client;

ü Income: Recalculate borrower(s) monthly gross income to determine if income was calculated and verified in accordance with the underwriting guidelines provided by the Client;

ü Appraisal Review: Consultant reviewed the appraisal to ensure conformity with the Client provided underwriting guides;

Ø Value Review Disclaimer: The individuals who performed the above procedures are not persons providing valuations for the purpose of the Uniform Standards of Professional Appraisal Practice (“USPAP”) or necessarily licensed as appraiser under Federal or State law, and the services being performed do not constitute appraisal reviews for the purposes of USPAP or Federal or State law. Consultant makes no representation or warranty as to the value of the mortgaged property, notwithstanding that Consultant may have reviewed the valuation information for reasonableness. Consultant is not an Appraisal Management Company (“AMC”) and therefore does not opine on the actual value of the underlying property. Consultant is not a creditor within the meaning of the Equal Credit Opportunity Act (“ECOA”) or other lending laws and regulations, and therefore Consultant will not have any communications with or responsibility to any individual concerning property valuations. Consultant does not check to see if any appraiser in on the Freddie Mac exclusionary list.

ü Assets: Confirmed the presence and verification of adequate asset documentation to comply with the Client provided underwriting guideline requirements for closing funds, reserves and borrower liquidity;

ü Debt Ratio: Recalculated the debt to income ratio and verified the ratio accuracy used by the loan underwriter at origination to determine compliance with Client provided underwriting guidelines;

ü Original Loan to Value (“LTV”) and Combined Loan to Value (“CLTV”) Ratios: Recalculated and verified the loan-to-value ratio and combined loan-to-value ratio were accurate at origination and met Client provided underwriting guidelines;

ü Credit History: Reviewed the credit report to verify that the borrower(s) demonstrated adequate credit depth to comply with the Client provided underwriting guideline requirements;

ü Credit Score: Verified that borrower(s) met the minimum credit score requirements to comply with the Client provided underwriting guides;

ü Document Inventory/Accuracy: The Consultant inventoried each closed loan file to ensure the documentation required by the Client provided underwriting guidelines were present. The Consultant audited all Notes, Riders, Addendums, Mortgage, Assignments, Modification Agreements, Assumption Documentation, Title Policy, & Deeds to ensure accuracy, completeness, proper interest conveyance, and appropriate lien position as required per closing instructions and in accordance with the Client provided

Opus CMC Privileged and Confidential Page 2

underwriting guidelines. If the subject property was either a Cooperative or Leasehold, the corresponding security agreements, abstracts, and land lease agreements shall be reviewed for completeness and accuracy. The Consultant reviewed the mortgage loan to ensure that it met the Client provided underwriting guides for hazard, flood, mortgage, or other insurance as applicable.

Misrepresentation Review: Validated that an independent fraud report was in the file and performed the following review:

ü Checked for signature variations between the imaged documents

ü Reviewed alerts on the credit report

ü Compared SSNs across all document in the loan file

ü Checked for apparent alterations to the imaged documents provided

ü Compared additional information located in the file provided for discrepancies potentially leading to misrepresentation

ü Reviewed third party fraud product provided and reviewed for any alerts and set conditions where applicable

Property Valuation Review: Reviewed each loan to determine whether a third party valuation product was required and if required, that the third party product value was compared to the original appraised value to identify a value variance. If a variance of more than 10% was noted, ensured any required secondary valuation product was ordered and reviewed. Applied the appropriate rating agency grade after reviewing the required valuation products.

During the Property Valuation Review, the Consultant identified 7 loans that had a Collateral Underwriter score through Fannie/DU of 2.5 or less. Due to this scoring, a third party valuation product was not ordered.

FEMA Declared Disaster Zones: If a FEMA declared disaster occured after the inspection date on the appraisal, Consultant reviewed the file to determine if an exterior inspection was present to ensure:

ü NO apparent damage to the property

ü Property appeared to be occupied.

Homeowner Flood Insurance Affordability Act (HFIAA): Each mortgage loan made by an FDIC-supervised institution or servicer acting on its behalf required the escrow of all premiums and fees for flood insurance for any designated loan secured by residential improved real estate or a mobile home, made, increased, extended or renewed on or after January 1, 2016.

National Flood Insurance Program (NFIP) – For loans originated prior to January 1, 2016, the mortgage loans were reviewed to ensure adherence to flood insurance coverage as outlined under NFIP, including identification of flood zones and subsequent policy documentation for evidence of adequate coverage amounts.

Multiple Loans to One Borrower: TPR firm reviewed common identifiers for all loans in the population and confirmed there were no obligors with multiple loans in the pool.

Regulatory Compliance: Each mortgage loan file was subject to a post-closing regulatory compliance review to verify that each mortgage loan closed in compliance with the applicable federal, state and local anti-predatory lending statutes in effect at the time of origination of the Mortgage Loan and that the loans meet the applicable disclosure requirements provided under MDIA, the federal Truth in Lending Act (“TILA”), as amended by HOEPA, 15 U.S.C. § 1601 et seq., as implemented by Regulation Z, 12 C.F.R. Part 226; (ii) Section 4 of the Real Estate Settlement Procedures Act (“RESPA”), 12 U.S.C. §2603, as implemented by Regulation X, 24 C.F.R. Part 3500; (iii) Fannie Mae points and fees limitations and HOEPA restrictions as addressed in Fannie Mae Announcement 04-06; (iv) the disclosure requirements and prohibitions of Section 50(a)(6), Article XVI of the Texas Constitution and associated regulations; and (v) the disclosure requirements and prohibitions of the applicable state, county and municipal laws and ordinances that were enacted to combat predatory lending

ü Section 32/HOEPA. Review included but was not necessarily limited to:

Ø APR test

Ø HPML test

Ø Points and Fees test

Ø Review of Section 32 disclosure for accuracy (i.e. payment stream, highest payment scenario; dates disclosed, dates acknowledged)

Ø Review and confirm documentation type (i.e. full, stated, no ratio)

Ø Review for evidence of prepayment penalty

Ø Verification of Debt to Income conformity, when necessary.

ü Federal Truth in Lending Act/Regulation Z. Review included, but was not necessarily limited to:

Opus CMC Privileged and Confidential Page 3

Ø A review of the material compliance disclosures set forth in the Truth in Lending Disclosure and the Notice of Right to Cancel, if applicable. A review and comparison of the initial and final TIL with a report outlining any TILA violations. Review includes a re-calculation of disclosed finance charge, proper execution by all required parties, principal and interest calculations, payment stream(s), recalculation of disclosed APR, and a review to ensure disclosure differences were within the allowed tolerances. A review of the Notice of Right to Cancel: Review included a verification of the transaction date and expiration date, ensured proper execution of the Notice of Right to Cancel by all required parties verified the disbursement date and determined if a full 3-day rescission period were adequately provided to the borrower(s).

ü S.A.F.E. Mortgage Licensing Act:

Ø Consultant performed a search of the mortgage loan originator and of the loan officer (“MLO”) in the www.nmlsconsumeraccess.org database in order to confirm that the MLO were appropriately licensed at the time of the mortgage loan’s origination and closing.

Seasoning and Certain Compliance Exceptions: Pursuant to the applicable NRSRO criteria, Consultant graded certain compliance exceptions as non-material based on 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 was not limited for claims, other than rescission, which are raised as a defense to foreclosure. Information contained in any Consultant reports 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 loan.

RESPA/Regulation X: Each mortgage loan was reviewed to ensure compliance with the January 1, 2010 or most current amendments to Regulation X. The RESPA/Regulation X review will consist of the following:

Good Faith Estimate (GFE) and Final HUD-1 Settlement Statement:

Ø Good Faith Estimate (GFE): The Consultant confirmed compliance with current RESPA requirements in effect at origination of the Mortgage Loan including

o Confirmed the presence of the current GFE form in effect at the time of origination.

o Verified the GFE was provided to the borrower(s) within three days of “Application”.

§ Application was defined by Regulation X and generally be considered complete when the following conditions are met (a) Borrower(s) First and Last Name (b) Borrower(s) Social Security Number (to enable the loan originator to obtain a credit report) (c) Subject Property Address (including “To Be Determined”) (d) Mortgage Loan Amount Sought (e) Estimation of Property Value (f) Monthly Income

o The Consultant verified that all Broker fees, including Yield Spread Premium (“YSP”) were accurately disclosed and reflected in the appropriate locations.

o Fees were reviewed to ensure they are reasonable and customary fees for the lender and title and escrow companies and that those fees were accurately disclosed on the GFE and were reflected in the proper location on the document.

o Analysis to determine whether a Changed Circumstance form were required to accompany each revised Good Faith Estimate (GFE)

Ø Final HUD-1: The Consultant confirmed compliance with current RESPA requirements in effect at origination of the Mortgage Loan including:

o Confirmed the presence of the current applicable Final HUD-1 form

o Confirmed the Final HUD-1 accurately lists all broker and YSP fees.

Ø Good Faith Estimate (GFE) and Final HUD-1 analysis: Confirm compliance with current RESPA requirements in effect at origination of the Mortgage Loan including:

o Analysis of Origination fees disclosed on the Good Faith Estimate (GFE) and those charged to the borrower(s) on the Final HUD-1 (no variance)

o Analysis of Third-Party fees disclosed on the Good Faith Estimate (GFE) and those charged to the borrower(s) on the Final HUD-1 (10% tolerance in variance)

o Analysis to confirm all fees are accurately reflected in the correct tolerance category on the Good Faith Estimate (GFE) and Final HUD-1

o Analysis to confirm lender accurately provided borrower adequate restitution in the event of tolerance violations and timelines for restitution/document correction were adhered to

o Analysis to confirm loan terms are accurately disclosed between the Good Faith Estimate (GFE) and Final HUD-1

Opus CMC Privileged and Confidential Page 4

o Analysis to confirm page 3 of the HUD-1 accurately reflects fees disclosed on the Good Faith Estimate (GFE) and Final HUD-1

Additional Regulation X Disclosures and Requirements: The Consultant confirmed compliance with current RESPA documentation and timing requirements in effect at origination of the Mortgage Loan including:

Ø Servicing Transfer Disclosure:

o Confirmed the presence of the Servicing Transfer Disclosure form in file

o Verified the Servicing Transfer Disclosure was provided to the borrower(s) within three general business days of “Application”

o Confirmed the Servicing Transfer Disclosure is executed by all applicants

Ø Special Information Booklet

o Confirmed the presence of the Special Information Booklet in file on Purchase and Construction (Construction to Perm loans) loans

o Confirmed the Special Information Booklet provided within three general business days of application

Ø Affiliated Business Disclosure

o Confirmed the presence of the Affiliated Business Disclosure in file in the event the lender has affiliated business arrangements

o Confirmed the Affiliated Business Disclosure provided within three general business days of “Application” (Consultant reviewed for this disclosure to be provided within three general business days, as the lender will typically know at the time of application if borrower(s) will be referred to affiliates for provision of third party services)

o Confirmed the Affiliated Business Disclosure is executed

Ø Initial Escrow Disclosure Statement

o Confirmed the presence of the Initial Escrow Disclosure Statement in file

o Confirmed the Initial Escrow Disclosure Statement was provided at closing or within 45 days after settlement

Statutory TILA RESPA Integrated Disclosure Review Procedures: Each mortgage loan was reviewed to ensure compliance with applications received October 3, 2015 or later (the earlier of the date the broker or lender received the borrower’s application). The TRID review consisted of the following:

Ø The Loan Purpose and Property Type included a closed-end mortgage secured by real estate:

o Purchase

o Refinance (Cash Out or Rate Term)

o Construction and Construction to Permanent Financing

o SFR, 1-4 Unit, PUD, Condo and Coops (Coop may be excluded based on Client instructions)

Ø The Loan Purpose and Property Type did not include:

o HELOCs

o Reverse mortgages

o Dwellings that are not attached to real property

o Mobile homes, where the consumer does not own the land,

Ø For purposes of determination of Occupancy, TRID applied to loans for owner occupied, second home and vacant land.

Ø Consultant applied the standard exemptions from TILA, i.e., business purposes loans, loans for agricultural purposes and loans secured by five (5) or more units.

o Please be aware that TILA contained a TRID-specific exemption for certain subordinate lien loans for the purposes of various types of assistance programs such as down payment or closing cost, property rehabilitation, energy efficiency or foreclosure avoidance or prevention. Consultant did not test such loans for TRID compliance.

Loan Estimate (″LE″)

Ø Initial LE

o Verification of compliance with timing requirements as to whether the Initial LE were delivered within three (3) business days from the Application Date. The Initial LE used the delivery date to calculate the earliest closing Consummation Date (no less than seven (7) business days from the delivery of the Initial LE). The delivery date was the date the creditor hand delivered the disclosures or placed the disclosures in the mail, 1026.19(e)(1).

Opus CMC Privileged and Confidential Page 5

Ø Revised LEs

o If there was a revision to the LE, validated that the Revised LE is provided within three (3) days of COC, BRC or interest rate lock. Reviewed as necessary for sufficient information to establish one of the six (6) valid reasons to reset tolerance fees set forth in TRID:

§ Changed Circumstance affecting settlement charges

§ Change Circumstance affecting eligibility

§ Revisions requested by the consumer

§ Interest rate dependent charges

§ Expiration of the LE and

§ Delayed settlement date on a construction loan

§ Timing Requirement for LE 7 days prior to consummation

Ø Determination of final binding LE

o Reviewed and analyzed each LE in file to determine final Binding LE. If there was a change in loan terms, change in interest rate or increase in charges subject to variances without valid reason for a Revised LE as set forth above, findings will be cited. If a Revised LE was issued without a valid reason, the previous valid LE would be considered the Binding LE for the purposes of comparison with the Closing Disclosure.

o Verification of compliance with timing requirements that there have been no loan estimates provided to the borrower after a Closing Disclosure has been delivered, and whether the Final LE was provided at least four (4) business days prior to the closing Consummation Date.

o If the LE did not contain a signature line for the consumer’s confirmation of receipt, then OPUS will look for the “Loan Acceptance” statement under “Other Considerations” or other client-documented acknowledgement and borrower intent to proceed.

o Verification that the correct form is used and all sections of the Initial LE are completed (no blanks, “NA’s” or incomplete sections) and the Initial LE is accurate as follows:

§ Verification of the technical formatting of the LE is NOT included in the standard review. The formatting of the document is the responsibility of the document preparation source.

§ General loan information and loan terms sections completed and formatting is accurate.

· Verify loan term, purpose, and product descriptions follow the prescribed format.

· Verify all applicants applying for credit, as disclosed on the application, are listed on the LE

o “Can this amount increase after closing?” and “Does the loan have these features?” sections are completed and are accurate based on the terms disclosed on the LE.

o If rate is locked, were lock expiration date, time and time zone disclosed.

o Settlement charges good through date, time and time zone disclosed with minimum of 10 days during which borrower was permitted to shop knowing fees were locked during that timeframe.

o Projected Payments and Estimated Taxes, Insurance & Assessments sections were complete and accurate based on the loan terms and information known at the time of disclosure.

o The Closing Costs and Cash-to-Close sections were completed and accurate based on the information provided on page 2 of the LE.

o Fees disclosed properly (alphabetical order within Section with certain exceptions, and all title fees start with ″Title – ″) in Closing Cost Details section.

§ It was recommended that an Itemization of Fees was provided for any fees disclosed as “Aggregate”. It ws quite difficult to determine if the fees were disclosed properly without this information.

o Any addenda found in file listing ADDITIONAL fees for sections other than Section C

o If Interest Only Payments, Optional Payments, Step Payments, or Seasonal Payments, is Adjustable Payment (″AP″) Table disclosed and accurate based on early disclosures in the file.

o If ARM or Step Rate, is Adjustable Interest Rate (″AIR″) Table disclosed and accurate based on the early disclosures in the file.

o The Comparison section was complete.

o Rounding rules verified as per 1026.37(o)(4).

o Other Considerations Section is complete

Written list of providers

Ø If the lender placed fees in the Services You Can Shop For category, verifed that the file contained a Written List of Providers provided to the borrower within three (3) business days of application. The WLSP must include at least one available provider for each service and state the consumer may choose a different provider for that service. If a written list of service

Opus CMC Privileged and Confidential Page 6

providers was not provided, the fees will be treated as a 10% Tolerance fee but a finding for missing service provider list will be noted. If a written list of service providers is provided outside of three (3) days of the application date, the fees will be treated was a 10% Tolerance fee but a finding for a service provider list being provided outside of three (3) days from application will be noted.

Variance Tests

Utilize one (1) of the following Variance Categories in performing variance tests:

o Zero Tolerance/Variance* - A finding was cited if any charges increased from the Binding LE to the Final CD without COC or BRC. Such increases include:

§ Fees paid to the lender, broker or an affiliate of either lender or broker

§ Fees paid to an unaffiliated third party if the lender did not permit the borrower to shop for servicer; and

§ Transfer taxes.

§ Lender Credits

o 10% Tolerance/Variance* – A finding was cited if the aggregate of the charges increased by more than 10% from the Binding LE to the Final CD without COC or BRC. If a fee/service was listed on the LE but not charged/reflected on the Final CD, the fee was removed and not considered in calculating the 10% variance threshold pursuant to Comment 19(e)(3)(ii)-5. Such increases include:

§ Recording fees; and

§ Charges for third party services not paid to creditor or affiliate AND borrower permitted to shop for service but selects a provider on the creditor’s Written List of Service Providers.

§ Prepaid mortgage insurance was treated as a 10% tolerance fee if it can be shopped for (and not identified as an affiliate), otherwise it will be treated as a zero tolerance fee.

o No Tolerance/Unlimited – No finding was cited if any of the charges changed from the Binding LE to the Final CD, provided that the disclosed amount on the LE was based on information reasonably known to the creditor at the time of disclosure (disclosed in good faith), such as:

§ Prepaid interest;

§ Property insurance premiums;

§ Impounds/Escrows;

§ Charges for services required by the creditor but the borrower was permitted to shop for and borrower selected a third party provider not on the lender’s Written Service Provider List; and

§ Charges for third party services NOT required by the creditor (even if paid to an affiliate of the creditor).

o Notes of interest for “No Tolerance/Unlimited”:

§ Prepaid property taxes charged by local and state governments periodically had no tolerance under the general ‘best information reasonably available’ standard unless otherwise instructed by the Client.

§ As noted above, Consultant reviewed the loan file for evidence the disclosure was not made in “Good Faith”. “Good faith” means the creditor made the estimate based on the information reasonably available to them at the time the LE was provided. Absent such evidence, Consultant considered the disclosures made in “good faith”. Two examples where a disclosure would be considered not made in “good faith” and a finding cited are:

o The creditor requires homeowner’s insurance but fails to include a homeowner’s insurance premium, a finding will be added that the LE was not issued in good faith.

o The creditor knows the loan must close on the 15^th of the month but estimates prepaid interest to be paid from the 30^th of that month, a finding will be added that the LE was not issued in good faith.

Additionally, if a documented valid COC or BRC occurs resulting in a change to loan terms, settlement charges or interest rate within four (4) business days of consummation, the variance test will be performed based on the revised amounts disclosed on the initial CD (or subsequent CD if change occurs after initial CD has been provided) provided that the change is related to the COC or BRC per Comment 19(e)(4)(ii)-1.

For loans with no Interim LE and no COC or BRC occurring four (4) days prior to consummation, fees and charges on the CD were tested for compliance with permitted variances against fees disclosed on Initial LE.

For loans with an Interim LE, the following procedures were applied:

o Review of each Interim LE and fees and charges on the CD were tested for compliance with variance thresholds against fees supported by a valid COC or BRC related to the charge that increases

o In cases where an Interim LE were issued with several fee increases, but only some are supported by or related to a valid COC or BRC, those fees which were not supported by or related to a valid COC, BRC or disclosed on an LE that was not provided timely (within three (3) business days of changed circumstance) will be tested for variance using the amounts disclosed in the Initial LE previously valid LE.

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Closing Disclosure (″CD″)

Consultant conducted a general CD reviewed and verified the following:

o Recommendation: Closing Disclosure provided at closing be marked “Final.” Although this was not a requirement, marking the Closing Disclosure as Final ensured a timely review.

o That the correct form was used and all sections of the CD were completed (no blanks or incomplete sections).

o Acknowledgement of receipt by all borrowers with a right to rescind under 1026.23 by verifying that each borrower with a right to rescind was provided with a copy of the CD. This could include the non-borrowing spouse. Acknowledgement was based on lender guidelines.

o If the CD did not contain a signature line for the consumer’s signature, Consultant looked for the required alternative statement in “Other Disclosures” with the heading of “Loan Acceptance”. While not required, Consultant highly recommends that the client required the CD to be signed and dated by the consumer as it will ensure a timely review.

o If a subsequent CD were issued having changes to (a) the loan product which affects disclosed terms and loan information; (b) the addition of a prepayment penalty; or (c) an APR which exceeds the previously disclosed APR by more than the permitted tolerances for accuracy, Consultant will test that the borrower was given an additional three (3)-business day waiting period from the date of final pre-close CD with (a) the final loan product; (b) the prepayment penalty addition; or (c) the APR, and that the final pre-close CD has been received by borrower by consummation.

o On the final CD the following checks and limitations apply:

o Verification of the technical formatting of the CD was out of scope in the standard review. The formatting of the document was the responsibility of the document preparation source.

o Closing, Transaction and Loan Information sections have been completed with accurate information.

o Loan terms sections were completed.

o Consultant verified loan term, purpose, and product descriptions follow the prescribed format.

o Consultant verified all applicants applying for credit, as disclosed on the application, are listed on the LE

o “Can this mount increase after closing?” and “Does the loan have these features?” sections were completed accurately.

o Projected Payments and Estimated Taxes, Insurance & Assessments sections are completed accurately.

o Fees have been disclosed properly (alphabetically, correct buckets and all title fees start with ″Title – ″) in Closing Cost Details section.

o Any addenda found in file listing ADDITIONAL fees for sections other than Section C (Services You Can Shop For).

o Calculating Cash to Close table completed accurately.

o Summaries of Transaction section completed accurately

o Loan Disclosures section complete:

o CD Assumption, Demand Feature, Negative Amortization, and Partial Payments sections completed properly (at least and only one box selected).

o Late Payment completed properly (terms disclosed and accurate per note).

o Escrow Amount section completed properly (only one box selected and amounts disclosed).

§ Escrow Property Costs over Year 1 to be calculated per the payments scheduled to be made in a 1-year period after consummation (1026.38)(I)(7)(i)(A)(1).

§ Non-Escrowed Property Costs over 1 Year to be calculated using either 11 or 12 months as determined by client. (1026.38)(I)(7)(i)(B)(1)

o If Interest Only, Optional Payments, Step Payments, or Seasonal Payments, was Adjustable Payment (″AP″) Table disclosed accurately.

o If ARM or Step, was Adjustable Interest Rate (″AIR″) Table disclosed accurately.

o Loan Calculations section complete and accurate.

o Total of Payments was accurate per 1026.38(o)(1).

§ Include fees in section A, B, and C that are paid by the borrower as well as the seller or other if those fees are customarily paid by the borrower.

o Capture amounts disclosed in Loan Calculations section and test for TILA tolerance violations on disclosed APR and Finance Charge.

o Total Interest Percentage (TIP) accurate with proper rounding.

o Other Disclosures section complete with at least one choice selected as applicable.

o Review for the creditor’s selection of one of the two options in the Liability After Foreclosure section, but will not make an independent judgement whether or not the selection is correct for the property state. Only issue a condition if either no selection is made or if both selections are made.

o Contact Information section was complete with information from each party of the transaction provided as applicable.

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o Rounding rules verified as per 1026.38(t)(4). Rounding on all percentages except APR was percentages should be truncated so that a zero was not disclosed in the last decimal place (7.250 should be rounded to 7.25).

TRID method of receipt of LE and CD

Determined the method of receipt of the revised LE and CD and performed a compliance test with timing requirements. For purposes of the review and verification, the date the borrower was deemed to have received the disclosure(s) was based on any of the following methods:

· In Person: borrower signature date was used.

· Electronic* - No Receipt Confirmation in File: three (3) business days from later of document issue date or proof of e-delivery date was used.

· Electronic* - With Receipt Confirmation in File, date of receipt confirmation was used.

· Electronic*-Delivery confirmation of an email, assuming the borrower(s) have consented to electronic delivery.

· Mail (USPS or other parcel delivery service) – No Receipt Confirmation in File: three (3) business days from later of document issue date or proof of mailing date was used. Delivery confirmation, i.e., confirmation that documents have been delivered to the borrower(s) door. Signature receipt by anyone other than the borrower(s) to the mortgage transaction constitutes evidence of delivery, not receipt, for the purposes of the receipt requirements.

· Mail (USPS or other parcel delivery service) – With Receipt Confirmation in File: date of receipt confirmation is used. Delivery confirmation, i.e., confirmation that documents have been delivered to the borrower(s) door. Signature receipt by anyone other than the borrower(s) to the mortgage transaction constitutes evidence of delivery, not receipt, for the purposes of the receipt requirements. Unknown (unable to determine delivery method or unable to verify borrower received disclosures in any other method than by USPS Mail method): follow the USPS Mail delivery method of three (3) business days from the document issue date. As noted above, a signature by anyone other than the borrower(s) constitutes evidence of delivery and the method of receipt will be considered unknown, requiring an additional three (3) days from the date the non-borrower received the documents.

NOTE: If disclosures were sent electronically, a finding will be cited if there was no evidence in the file that the borrower consented to receive disclosures electronically. Default to the three (3) business day mail rule for delivery without the proper documentation of borrower consent.

Other recommended TRID compliance tests

Apply the following additional compliance tests which were included in the recommended review scope resulting from the 2015 CFPB Amendments:

· Use of TRID forms prior to TRID effective date: a finding was cited if the new TRID forms were utilized on a loan with an application received prior to the October 3, 2015 effective date.

· Use of TRID forms on loans not covered by TRID: a finding was cited if the new TRID forms were utilized on loans not covered by TRID (i.e., HELOC, i.e. reverse mortgages, i.e. Chattel Dwelling loans (loans on mobile homes that were not also secured by the underlying real property or loans on houseboats).

· Your Home Loan Toolkit: a finding was cited if the new Your Home Loan Toolkit Disclosure or evidence the disclosure was delivered or placed in the mail was not in the file or was not provided to the borrower within three (3) business days of application.

· Consummation Date: Consummation varies by applicable state law and the term is not often clearly defined. Accordingly, generally use the notary date. If there were multiple borrowers and they did not all sign the documents on the same day, then used the latest signature date.

· Post-Consummation Disclosures: TRID review scope did not include testing for compliance with the following post-consummation disclosures under TRID:

o Escrow Closing Notice; and

o Mortgage servicing transfer and partial payment notices.

Subsequent changes after consummation

The following prescribed cures as set forth in section 1026.19 (f)(2)(iii) through (v) were acceptable for changes and corrections to the Final CD after consummation.

· 1026.19(f)(2)(iii) – Changes due to events occurring after consummation.

o If within 30 days of consummation, an event in connection with the settlement of the transaction occurred that caused the final CD to become inaccurate and such inaccuracy results in a change to an amount actually

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paid by the borrower(s) from the amount disclosed, test for evidence that a new, corrected CD was delivered or placed in the mail to the borrower within thirty (30) days of receiving information that an event occurred.

· 1026.19(f)(2)(iv) – Changes due to clerical errors.

o Non-numeric clerical errors, for the purpose of this scope document were any errors not related to a disclosed dollar amount or percentage. Test for evidence a new, corrected CD is delivered or placed in the mail to the borrower within sixty (60) calendar days of consummation. Examples of non-numeric clerical errors include but are not limited to:

§ Corrections to the closing information section.

§ Corrections to the transaction information section.

§ Corrections to loan id # or MIC #.

§ Corrections to non-numeric identifiers in the Estimated Taxes, Insurance & Assessments section.

§ Corrections to the fee labels and/or order of fees.

§ Corrections to the location of the fee(s).

§ Corrections to missing cure language.

§ Corrections to the “Did This Change” section of Calculating Cash to Close.

§ Corrections to the Loan Disclosures section

§ Corrections to non-numeric items in the Escrow Account section.

§ Corrections to the Other Disclosures section.

§ Corrections to the Contact Information section.

· 1026.19(f)(2)(v) – Refunds related to the good faith analysis.

o Test for evidence such as a copy of the refund check, a new corrected CD, and evidence the creditor delivered or placed in the mail to the borrower within sixty (60) calendar days of consummation.

A post-consummation CD was understood to be a re-issued CD with a Date Issued represented as the date the post-consummation CD was issued. Corrections to the final pre-close CD were not be accepted as a post-consummation CD noted in the prescribed cures above.

Errors on LE’s and Interim CD’s and numeric errors on final CD’s which did not have prescribed cures as per the regulation were not reported as having been cured. The assessment of risk and decision to accept a finding that does not have a prescribed cure was the responsibility of the purchaser of the loan.

SFIG TILA RESPA Integrated Disclosure Review Procedures:

The Consultant reviewed TRID loans using loan level grading, cure provisions and general guidance associated with proposed TRID Compliance Review Scope issued by The Structured Finance Industry Group (hereinafter known as SFIG). The Customer acknowledges that the SFIG guidance was “proposed”, was not finalized and reflects potential for amendments based on additional rule making or guidance from the CFPB or adjudication from the U.S. Supreme Court that may over turn prevailing U.S. Circuit Court rulings.  The Client accepted and understood the potential risks associated with any potential future amendments resulting from guidance or rulings from the Bureau or the courts.

High Cost - State & Local Anti-Predatory Regulations: In addition to federal thresholds, the Consultant reviewed the anti-predatory lending statutes in the following states and local municipalities, as applicable, as well as any additional applicable regulations implemented during the Term of this SOW:

Ø Arkansas Home Loan Protection Act, Ark. Stat. Ann. § 23-53-101 et seq.

Ø California Anti-Predatory Lending Statute, Cal. Fin. Code § 4970 et seq.

Ø Colorado Consumer Equity Protection Act, Colo. Rev. Stat. § 5-3.5-101 et seq. and as amended by Senate Bill 216 (2007) and House Bill 1322 (2007).

Ø Colorado Consumer Credit Code, Colo. Rev. Stat. 5-1-101 et seq.

Ø Connecticut Abusive Home Loan Lending Practices Act, Conn. Stat. Ann. §36a-746 et seq. and the Responsible Lending and Economic Security Act, Conn. House Bill 5577 (2008).

Ø District of Columbia Home Loan Protection Act of 2002, D.C. Official Code § 26-1151.01 et seq., as implemented by 20 D.C. Municipal Reg. § 2000.1 et seq. as well as DC Mortgage Disclosure Act of 2007.

Ø Florida Fair Lending Act, Fla. Stat. Ann. § 494.0078 et seq.

Ø Georgia Fair Lending Act, Ga. Stat. Ann. § 7-6A-1 et seq. (as originally enacted by House Bill 02-1361 and as modified by Senate Bill 03-53)

Ø Idaho Residential Mortgage Practices Act, Idaho Code § 26-3101 et seq.

Ø Illinois High Risk Home Loan Regulations, 38 Ill. Admin. Code § 345.10 et seq.

Ø Illinois High Risk Home Loan Act, Public Act. 93-0561 (2003).

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Ø City of Chicago, Illinois, Anti-Predatory Lending Ordinance, Chicago Municipal Code, §§ 2-32-440; 2-32-455; 2-92-325; 4-4-155; 8-4-325.

Ø Cook County, Illinois, Anti-Predatory Lending Ordinance, Ordinance No. 240864 (2001) as amended by Illinois SB 1167 (2007).

Ø Indiana Home Loan Practices Act, Ind. Code § 24-9-1 et seq.

Ø Section 16a-3-308a of the Kansas Consumer Credit Code, Kan. Stat. Ann. § 16a-1-101 et seq. 16. Kentucky Anti-Predatory Lending Statute, Ky. Rev. Stat. § 360.100 et seq. and as amended by Kentucky House Bill 552 (2008).

Ø Maine, An Act to Enhance Consumer Protections in Relation to Certain Mortgages, 9A Me. Rev. Stat. Ann. §§ 8-103(1); 8-206(8); 8-206A and Maine Legislative Document 1869 (2007).

Ø Maryland Commercial Law, Mary. Stat. Ann. §§ 12-124.1; 12-127; 12-409.1; 12-1029 and as amended by Maryland Senate Bill 270 (2008) and Maryland Regulations under the Maryland Mortgage Lender Law (2009).

Ø Massachusetts High Cost Mortgage Regulations, 209 CMR § 32.32 et seq. including MA House Bill 4387 (2008) 20. Massachusetts Predatory Home Loan Practices Act, M.G.L. Chapter 183(C).

Ø Massachusetts “Borrower’s Interest” Standard, M.G.L. Chapter 183, §28C.

Ø Michigan Consumer Mortgage Protection Act, Mich. Stat. Ann. § 445-1631 et seq.

Ø Minnesota Mortgage Originator and Service Licensing Act, § 58.137 et al. (S.F. 2988 (2002) and as amended by House File 1004 and SF 98 (2007) and SF 3154 and 3214 (2008).

Ø Nebraska Mortgage Bankers Registration and Licensing Act, Neb. Stat.§ 45-702 et seq.

Ø Nevada Anti-Predatory Lending Law, Nev. Rev. Stat. § 598D.010 et seq. and as amended by AB 440.

Ø New Jersey Home Ownership Security Act of 2002, NJ Stat. Ann. § C:46:10B-22 et seq.

Ø New Mexico Home Loan Protection Act, N.M. Stat. Ann. § 58-21A-1 et seq. and as amended by Senate Bill 342 (2009).

Ø New York High Cost Home Loan Regulations, 3 NYCCR Part 41 (2001).

Ø New York High Cost Home Loan Act, N.Y. Bank. L. Ch. 626., as implemented by 3 NYCCR Part 41 (2003) and as amended by Senate Bill 8143-A (2008).

Ø North Carolina Anti-Predatory Lending Law, N.C. Gen. Stat. §§ 24-1.1A to 24-10.2 and North Carolina Amendments to Anti-Predatory Lending Law, N.C. Gen. Stat. §§ 24-9; 24-1.1(E)(a); 24-10.2(a) and as amended by House Bill 1817 (2007).

Ø Ohio Anti-Predatory Lending Statute, Ohio Rev. Code Ann. § 1.63 and as amended by S.B. 185.

Ø City of Cleveland Heights, Ohio, Anti-Predatory Lending Ordinance, Ordinance No. 72-2003.

Ø Oklahoma Anti-Predatory Lending Law, House Bill No. 1574 (2003).

Ø Pennsylvania Consumer Equity Protection Act, 63 Pa. Cons. Stat. Ann. § 456.501 et seq.

Ø City of Providence, Rhode Island Predatory Lending Ordinance, Ordinance No. 245, Chapter 2006-33 as amended.

Ø Rhode Island Home Loan Protection Act, Chapter 25.2 of Title 34 of RI Gen. L. et seq., including the Emergency and Final Regulations.

Ø South Carolina High-Cost and Consumer Home Loans Act, S.C. Code § 37-23-10 et seq.

Ø South Carolina Consumer Protection Code, S.C. Code 37-1-101 et seq

Ø Tennessee Home Loan Protection Act of 2006, TN Code Annotated, Title 47 et seq.

Ø Texas High-Cost Home Loan Statute, TX. Fin. Code Ann. § 343.201 et seq.

Ø Utah Residential Mortgage Practices Amendments, Utah Code Ann. § 61- 2c-102 et seq.

Ø Utah High Cost Home Loan Act, Utah Code § 61-2d-101 et seq.

Ø Vermont Interest Act, 9 V.S.A. § 104, implemented by Regulation B-98-2.

Ø Virginia Mortgage Lender and Broker Act (for loans originated prior to July 1, 2003), Va. Code Ann. §§ 6.1-413; 6.1-422, 6.1-428.

Ø Virginia Mortgage Lender and Broker Act (for loans originated after July 1, 2003), Va. Code Ann. §§ 6.1-411; 6.1-422.1, 6.1-425.1; 6.1-425.2.

Ø Washington House Bill 2770, Mortgage Lending and Homeownership, Chapter 108, Laws of 2008.

Ø Wisconsin Responsible High Cost Mortgage Lending Act, Wis. Stat. § 428.202.

Ø West Virginia Residential Mortgage Lender, Broker and Servicer Act, W.Va. Code § 31-17-1 et seq.

Ø Wyoming Credit Code, Wyo. Stat. Ann. §§ 40-14-101 et seq.

Dodd-Frank Act: The consultant reviewed each mortgage for compliance with the rules established under the Dodd-Frank Act for Ability-to-Repay and Qualified Mortgage requirements, 12 CFR 1026.43. The review consisted of the following:

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ü Ability to Repay: Assess the Ability-to-Repay (“ATR”) of each borrower for transactions which fall outside of the Qualified Mortgage (“QM”) rule. The review consisted of the following:

o ATR Verifications

§ Verification of the Ability-to-Repay were considered based on a review of the following criterial: (1) income and assets, (2) current employment status, (3) monthly payment on covered loan, (4) monthly payment on simultaneous loan, (5) monthly payment for mortgage related obligations, (6) current debt, alimony and child support, (7) DTI or residual income, and (8) credit history.

o ATR Credit Exceptions

§ Verified that no lender based credit exceptions are present and/or approved.

o ATR Rating

§ ATR test results were provided by grading each loan’s ATR compliance as: ATR-Pass, ATR-Fail and ATR Exempt.

ü Qualified Mortgage: Evaluated each loan seeking QM status to validate compliance with requirements of the Qualified Mortgage (“QM”) regulations for Temporary Qualified Mortgages (“TQM”), Small Creditor Qualified Mortgages (“SCQM”) and Small Creditor Balloon Qualified Mortgages (“BQM”). This review consisted of the following:

Ø Product Features

o Verified that loans seeking QM status not allow for interest only loan terms, negative amortization loans, balloon terms or terms exceeding 30 years.

Ø Debt-to-Income Ratios

o Verified that debt-to-income ratios did not exceed 43%.

Ø Points and Fees

o Verified that loans seeking QM status did not contain charges to the borrower that exceed the 3 percent of the total loan amount for a loan greater than or equal to $100,000, $3,000 for a loan greater than or equal to $60,000 but less than $100,000, 5 percent of the total loan amount for a loan greater than or equal to $20,000 but less than $60,000, $1,000 for a loan greater than or equal to $12,500 but less than $20,000, or 8 percent of the total loan amount for a loan less than $12,500. (2014 – subject to annual adjustments in subsequent years)

ü Temporary Qualified Mortgage: Verified that loans made from the government and the GSEs met all applicable guideline requirements in lieu of the 43% debt-to-income ratio cap including guidelines regarding: LTV/CLTV, DTI, Credit Score, Reserves, Max Loan Amount, the maximum cash out amount and minimum disposable income requirements.

Ø QM & ATR Reporting

o Upon review of the related documents and QM and ATR testing standards, verified the QM/ATR status in the credit rating agency format as follows:

· QM – NonHPML

QM or TQM – Pass / HPML – No or QM/Agency Safe Harbor

· QM – HPML

QM or TQM – Pass / HPML – Yes

· NonQM – Compliant

QM or TQM – Fail, Exempt / ATR – Compliant

· NonQM – Noncompliant

QM or TQM – Fail, Exempt / ATR – Noncompliant

· Not covered – Exempt

QM or TQM – Exempt / ATR – Exempt

Ø Higher Priced Mortgage Loans

o Determined whether each loan would be considered a Higher Priced Mortgage Loan (“HPML”). A loan APR which exceeds the Average Prime Offer Rate by 1.50% or more percentage points on conforming First Liens and 3.50% or more percentage points on Second Liens. For FHA TQM, the formula is modified to be the Average Prime Offer Rate plus 1.15%, plus the monthly MI premium factor.

Ø Escrow Requirements

o Verified that all HPML loans have escrow accounts established for the first five years of the life of the loan.

Ø HPML Appraisal Rules

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o Verified that all HPML loans meet the following additional appraisal rules: borrower’s right to receive the appraisal report, written appraisal from a certified or licensed appraiser, evidence of an interior inspection, delivery of copies no later than 3 days from consummation, and a 2^nd appraisal detailing improvements, market conditions and change in sale price for loans that meet the “flipping” definition.

Ø Loan Originator Compensation

o Verified disclosed compensation is permissible. Verified disclosed compensation in Points and Fees testing as appropriate. Verified Loan Originator and Loan Originator Organization licensing status as well as proper disclosure on the application, note and mortgage as per applicable Safe Act and Loan Originator regulations.

ü Regulatory Compliance Disclaimer: Please be advised that Consultant will not make a determination as to whether loans complied with federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated herein. There can be no assurance that the review uncovered all issues relating to the origination of the mortgage loans, their compliance with applicable law and regulation and the original appraisals relating of the mortgaged properties or uncovered all relevant factors that could affect the future performance of the mortgage loans. Furthermore, the findings reached by Consultant are dependent upon its receiving complete and accurate data regarding the mortgage loans from loans originators and other third parties upon which Opus is relying in reaching such findings. Please be further advised that Consultant does not employ personnel who are licensed to practice law in various jurisdictions, and the findings set forth in the reports prepared by Consultant do not constitute legal advice or opinions. They are recommendations or conclusions based on information provided to Consultant. 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 potential liability related to the purchase or other transaction involving any such loans, shall be made solely by the Client, or other agreed upon party, that has engaged Consultant to prepare its reports pursuant to its instructions and guidelines. Client, or other agreed upon party, acknowledges and agrees that the scoring models applied by Consultant 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

Data Integrity: Consultant compared the data supplied on the bid tape provided by the Client to the documents contained in the loan file. If the comparison revealed discrepancies, these were reconciled by Consultant and reported as a data difference and the final data tape updated accordingly. Data elements for comparison were determined on an “as available” basis and upon mutual agreement between Consultant and Client.

Pool Details

Loan Type			Product Type
Type	Count	% of Pool	Type	Count	% of Pool
Non-Conforming	9	100.00%	Fixed	9	100.00%
Conforming-GSE Eligible	0	0.00%	ARM	0	0.00%
Total	9	100.00%	Total	9	100.00%
Interest Rate			Occupancy
Type	Count	% of Pool	Type	Count	% of Pool
2.250 - 2.499	0	0.00%
2.500 - 2.999	0	0.00%	Primary Residence	9	100.00%
3.000 - 3.499	0	0.00%	Second Home	0	0.00%
3.500 - 3.999	1	11.11%	Investment Property	0	0.00%
4.000 - 4.499	2	22.22%
4.500 - 4.999	5	55.56%	Total	9	100.00%
5.000 - 5.499	1	11.11%
5.500 - 5.999	0	0.00%
6.000 - 6.499+	0	0.00%
Total	9	100.00%

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			Property Type
Purpose			Type	Count	% of Pool
Type	Count	% of Pool	Single Family Detached	6	66.67%
Cash out Refi	4	44.44%	Co-op	0	0.00%
Purchase	1	11.11%	Condo, Low Rise	0	0.00%
Rate / Term Refi	4	44.44%	Condo, High Rise	0	0.00%
Total	9	100.00%	PUD	3	33.33%
			1 Family Attached	0	0.00%
			2 Family	0	0.00%
			3 Family	0	0.00%
			4 Family	0	0.00%
			Total	9	100.00%
DTI
Type	Count	% of Pool
0.00-20.00	0	0.00%	LTV
20.01-30.00	1	11.11%	Type	Count	% of Pool
30.01-40.00	3	33.33%	0-30.00	0	0.00%
40.01-43.00	5	55.56%	30.01-40.00	0	0.00%
43.01-50.00	0	0.00%	40.01-50.00	0	0.00%
Total	9	100.00%	50.01-60.00	0	0.00%
			60.01-70.00	2	22.22%
			70.01-80.00	7	77.78%
			80.01-90.00	0	0.00%
			Total	9	100.00%

QM Type
Type	Count	% of Pool
QM/Non-HPML	9	100.00%
QM/Agency Safe Harbor	0	0.00%
Total	9	100.00%

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Tape Discrepancies

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Loan Grading Definitions

Credit

S&P	Moody’s	Fitch	Kroll	DBRS	Definition
A	A	A	A	A	Loan conforms to all applicable guidelines, no conditions noted
B	B	B	B	B	Loan does not meet every applicable credit guideline.  However, most of the loan characteristics are within the guidelines and there are documented and significant compensating factors
C	C	C	C	C	The loan does not meet every applicable credit guideline, and most of the loan characteristics are outside of guidelines; or there are weak or no compensating factors
D	D	D	D	D	The loan file is missing critical documentation required to perform the review

Compliance

S&P	Moody’s	Kroll	DBRS	Definition
A	A	A	A	The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
B	B	B	B	The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations; however, minor evidentiary issue(s) exist
C	C	C	C	The includes material violation(s) with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
D	D	D	D	The loan file is missing critical documentation required to perform the review

Fitch	Definition
A	The loan was originated in compliance with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
B	The loan is in compliance with all applicable laws and regulations and a benefit to the borrower is present and documented
C	The includes material violation(s) with applicable federal, state, and local predatory and high cost, TILA, and Regulation Z laws and regulations
D	The loan file is missing critical documentation required to perform the review

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Property Valuation

Moody’s	Fitch	Kroll	DBRS	Definition
A	A	A	A	Value is within a 10% variance of third party product. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete.
B	B	B	B	Meets all terms for an A, but property requires cosmetic or minor repairs that do not effect value or habitability
C	C	C	C	Any of the following items: Origination value and third party valuation product value has a variance of 10% or greater, cannot validate value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not meet guidelines
D	D	D	D	The loan file was missing the appraisal and/or other valuations products needed to complete the review

S&P	Definition
A	First Level Review Value is within a 10% variance to the original appraisal. Appraisal meets lender guidelines. Subject property is 100% complete. Property condition is average or better. Standard GSE form was utilized. Appraiser is licensed. Appraisal is complete.
B	First Level Review Value is greater than a 10% variance to the original appraisal but the second level review value is within 10% variance of the original appraised value. In addition, property requires cosmetic or minor repairs that do not effect value or habitability
C	Any of the following items: Second Level Review Value is greater than a 10% variance to the original appraisal, cannot validate value, property is incomplete, property condition is less than average, GSE form was not utilized, and/or the appraisal and/or does not meet guidelines
D	The loan file was missing the appraisal and/or other valuations products needed to complete the review

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Loan Review Findings

The following summarizes Consultant’s initial and final loan securitization and event grades assigned to the final reviewed loan pool and reported in the Grading Summary Report dated September 19, 2019.

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Loans Reviewed (9)

If you have any questions, please contact Elisha Werner at Elisha.Werner@opuscmc.com

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EX-99.4

Exhibit 99.4 - Schedule 1

Client Loan Number

Channel

Rate Lock Date

Application Date

Borrower Employment Indicator

Co Borrower Employment Indicator

Borrower Citizenship Indicator

Co Borrower Citizenship Indicator

Residual Income

Points And Fees

Points And Fees Without Reductions

APR

Qualifying Interest Rate

Average Prime Offer Rate

GSE Eligibility

Opus QM ATR Status

S&P QM ATR Status

Fitch QM ATR Status

Moodys QM ATR Status

TRID

301155663

Wholesale

XXXX

XXXX

Employed

Employed

US

US

10004.716

6320

6320

0.04441

0.04375

4.34

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

301159179

Correspondent Flow without delegated underwriting

XXXX

XXXX

Employed

Non Permanent Resident Alien

5703.942

1800

1800

0.0495

0.04875

4.21

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

301150504

Wholesale

XXXX

XXXX

Employed

US

12406.017

9044.4

9044.4

0.04526

0.045

4.45

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

301133752

Wholesale

XXXX

XXXX

Employed

Employed

US

US

8950.618

13205

13205

0.05028

0.04875

4.4

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

301158639

Wholesale

XXXX

XXXX

Employed

Unemployed

Permanent Resident Alien

US

7584.042

1626.23

1626.23

0.03775

0.0375

4.31

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

301150076

Correspondent Flow without delegated underwriting

XXXX

XXXX

Employed

US

11665.285

1975

1975

0.05322

0.0525

4.39

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

301158540

Wholesale

XXXX

XXXX

Employed

US

7322.785

7980

7980

0.04483

0.04375

4.31

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

301154813

Wholesale

XXXX

XXXX

Employed

US

6667.866

6210

6210

0.0477

0.0475

4.34

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

301147129

Wholesale

XXXX

XXXX

Employed

Unemployed

US

US

8262.491

11232

11232

0.04894

0.04875

4.39

No

QM/Non-HPML

QM/Non-HPML

SHQM

QM Safe Harbor

Yes

EX-99.4

Exhibit 99.4 - Schedule 2

Client Loan Number	Data Field	Tape Data	Review Data	Tape Discrepancy Comments
301133752	CLTV	72.54%	72.55%	1st lien of $XXXXXX / Value of $XXXXXXX = CLTV of 72.55%
301133752	DTI	40.78%	42.85%	1008 DTI 42.848%.  Rounding.
301133752	LTV	72.54%	72.55%	Loan amount taken from note
301133752	Number of Borrowers	1	2	Number of Borrowers taken from note
301133752	Original Payment	Per Tape	Per Data	Audit Value is Orig. Payment from Note
301147129	DTI	38.15%	42.92%	1008 DTI 42.924%.  No discrepancy
301147129	Number of Borrowers	1	2	Two borrowers per Note
301150504	Appraised Value	Per Tape	Per Data	Value Pulled From Appraisal In File
301150504	CLTV	74.32%	77.81%	1st lien of $XXXXXX + 2nd lien of $0 / Value of $XXXXXX = CLTV of 77.81%
301150504	DTI	30.00%	26.57%	1008 DTI 26.574%; rounding.
301150504	LTV	74.32%	77.81%	Loan amount taken from note.
301150504	Original Payment	Per Tape	Per Data	Audit Value is Orig. Payment from Note
301150504	Property Type	Single Family Detached	PUD	Appraisal Reflects PUD
301155663	Appraised Value	Per Tape	Per Data	Value Pulled From Appraisal In File
301155663	CLTV	74.58%	76.96%	1st lien of $XXXXXX  / Value of $XXXXXXX = CLTV of 76.96%
301155663	DTI	39.83%	39.97%	1008 DTI 39.97%.  No discrepancy.
301155663	FICO	770	723	Audit utilized the lower of the mid score for both borrowers’.
301155663	LTV	74.58%	76.96%	Loan amount taken from Note
301155663	Number of Borrowers	1	2	Number of Borrowers taken from note
301155663	Original Payment	Per Tape	Per Data	Audit Value is Orig. Payment from Note
301154813	Appraised Value	Per Tape	Per Data	Value Pulled From Appraisal In File
301154813	CLTV	75.00%	67.86%	1st lien of $XXXXXX / Value of $XXXXXXX = CLTV of 67.86%
301154813	DTI	42.59%	42.85%	108 DTI 42.847%.  Rounding.
301154813	LTV	75.00%	67.86%	Loan amount taken from note.
301158639	CLTV	75.39%	75.68%	1st lien of $XXXXXX / Value of $XXXXXX = CLTV is 75.68%
301158639	DTI	35.00%	42.43%	1008 Value 42.43 matces audit
301158639	Interest Rate	4.250%	3.750%	taken from note
301158639	LTV	75.39%	75.68%	Loan amount taken from note.
301158639	Number of Borrowers	1	2	Taken from Note
301158639	Original Balance	Per Tape	Per Data	taken from note
301158639	Original Payment	Per Tape	Per Data	Audit Value is Orig. Payment from Note
301158540	Appraised Value	Per Tape	Per Data	Value Pulled From Appraisal In File
301158540	CLTV	70.30%	78.11%	1st lien of $XXXXXX / Value of $XXXXXX = CLTV of 78.11%
301158540	DTI	29.32%	37.93%	1008 DTI 37.933% .  No discrepancy.
301158540	LTV	70.30%	78.11%	Loan amount taken from note.
301150076	DTI	26.16%	30.30%	1008 DTI 30.30%.  No discrepancy.
301159179	CLTV	80.00%	79.40%	1st lien of $XXXXXX/ Value of $XXXXXX = CLTV of 79.40%
301159179	DTI	42.89%	42.96%	1008 DTI 42.96%.  No discrepancy.
301159179	LTV	80.00%	79.40%	Loan amount taken from note.
301159179	Original Balance	Per Tape	Per Data	Loan amount taken from note
301159179	Original Payment	Per Tape	Per Data	Audit Value is Orig. Payment from Note
301159179	Property Type	Single Family Detached	PUD	Appraisal Reflects PUD

EX-99.4

Exhibit 99.4 - Schedule 3

Client Loan Number

Exception ID

Loan Status

Originator QM/ATR Status

TPR QM/ATR Status

Finding Group

Status

Moodys Final Exception Grade

Fitch Final Exception Grade

SP Final  Exception Grade

Kroll Final Exception Grade

DBRS Final Exception Grade

Category

Finding Name

Initial Comment

Client/Seller Reponse Comments

Conclusion Comment

Compensating Factors Merged

301133752

95f9ebe3-3070-e911-bdd2-f4e9d4a75ba2

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Property

Cleared

A

A

A

A

A

Property

570 - Review Appraisal Missing

A CDA report was not provided in the file.  CU Risk Score is 4.3.

05/10/2019: The AVM report value of $XXXXXXX to appraisal value of $XXXXXXX has variance which is less than maximum tolerance variance threshold of 10%. Confidence factor is within guidelines. AVM report is acceptable. Condition cleared.

301147129

7938db0e-435d-e911-bdd2-f4e9d4a75ba2

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Credit

Cleared

A

A

A

A

A

Credit

Missing Documentation

Executed Home Equity Line of Credit (HELOC) closure letter reflecting HELOC was frozen and closed was not provided in the file.

05/01/2019: Missing doc provided4/17/2019:  see attached

05/01/2019: Missing doc provided, condition cleared. 04/18/2019:  The closure letter provided belongs to a different buyer/loan.  Condition remains.

Years on Job Borrower has 12 years on job Full Documentation The loan is full documentation

301154813

08dc8ae5-f67a-e911-bdd2-f4e9d4a75ba2

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Credit

Cleared

A

A

A

A

A

Credit

Missing Documentation

Executed Home Equity Line of Credit (HELOC) closure letter reflecting HELOC was frozen and closed was not provided in the file.

05/30/2019: See attached

05/30/2019: Audit reviewed executed HELOC Closure Authorization, and has determined that the document requests the closure and lien release of said HELOC account. Condition cleared.

FICO is higher than guideline minimum UW Guides require FICO of 700, loan qualified with FICO of 732 Reserves are higher than guideline minimum UW Guides require no months reserves, loan qualified with  11.80 months reserves Years in Field Borrower has 18 years in Field

301154813

8674d863-fb7a-e911-bdd2-f4e9d4a75ba2

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Credit

Cleared

A

A

A

A

A

Credit

Missing AUS results

Missing AUS results.  The Mortgage Information section of the AUS is missing.

05/28/2019: See attached

05/28/2019: Audit reviewed complete copy of the AUS, and has determined that the documentation submitted is deemed acceptable. Condition cleared.

FICO is higher than guideline minimum UW Guides require FICO of 700, loan qualified with FICO of 732 Reserves are higher than guideline minimum UW Guides require no months reserves, loan qualified with  11.80 months reserves Years in Field Borrower has 18 years in Field

301158639

aa9f7008-8e7d-e911-bdd2-f4e9d4a75ba2

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Credit

Cleared

A

A

A

A

A

Credit

Failure to obtain 3rd party verification of employment

• The lender must verify the existence of the borrower's business within 120 calendar days prior to the note date - from a third party, such as a CPA, regulatory agency, or the applicable licensing bureau, if possible; or - by verifying a phone listing and address for the borrower's business using a telephone book, the Internet, or directory assistance. • The lender must document the source of the information obtained and the name and title of the lender's employee who obtained the information.   The item required in the second bullet point was not provided and the business license was not dated.

5/30/19 See attached verification of the UW that verified the VOB and it is dated within 30 days of the note.

06/03/2019:  Received satisfactory verification of business.  Timing requirement met, condition cleared.06/03/2019:  Received verification of business, date verified and name of employee. Title of the lender’s employee not provided.  Condition remains.

DTI is lower than guideline maximum UW Guides maximum DTI of 43%, loan qualified with DTI of 37.64% FICO is higher than guideline minimum UW Guides require FICO of 700, loan qualified with FICO of 715 Years in Field Borrower has 13 years in Field

301158639

8c42a2ab-537d-e911-bdd2-f4e9d4a75ba2

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Credit

Cleared

A

A

A

A

A

Credit

Missing Executed Business Returns

Per Appendix Q, Self-employed consumers must provide the following information:  signed, dated individual tax returns, with all applicable tax schedules for the most recent two years;  for a corporation, “S” corporation, or partnership, signed copies of Federal business income tax returns for the last two years, with all applicable tax schedules.  XXXX complete and signed business returns not provided for the borrower's partnership as referenced as LOE from borrower on page 131.

06/13/2019:  Received signed XXXX partnership return and complete XXXX/XXXX partnership returns.  Condition cleared.06/03/2019:  Received executed page 1 for XXXX partnership tax return.  A review of the file found partial pages to XXXX/XXXX partnership returns on pages 50-60, 223-246 and 313-322.  Missing all pages to XXXX/XXXX returns and missing signed XXXX return.  Condition remains.

DTI is lower than guideline maximum UW Guides maximum DTI of 43%, loan qualified with DTI of 37.64% FICO is higher than guideline minimum UW Guides require FICO of 700, loan qualified with FICO of 715 Years in Field Borrower has 13 years in Field

301150076

53b98711-a26b-e911-bdd2-f4e9d4a75ba2

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Credit

Cleared

B

B

B

B

B

Credit

Missing Documentation

Executed Home Equity Line of Credit (HELOC) closure letter reflecting HELOC was frozen and closed was not provided in the file.

05/15/2019: Please see attached credit report showing it's paid and closed.

05/15/2019: Audit reviewed Post Closing credit report, and has determined that said document verifies HELOC account has been paid and closed. Loan will be rate a B.

CLTV is lower than guideline maximum UW Guides maximum CLTV of 80%, loan qualified with CLTV of 70% DTI is lower than guideline maximum UW Guides maximum DTI of 43%, loan qualified with DTI of 30.30% Years in Primary Residence Borrower has resided in subject for 10 years

301150076

dbd75cf1-318c-4d1f-a3a3-44c027a8c1d1

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Compliance

Cleared

A

A

A

A

A

Compliance

Missing Affiliated Business Disclosure

File is missing the Affiliated Business Disclosure.  If the lender is not affiliated with any other businesses, please provide an attestation stating such.

05/06/2019: please see attached attestation letter which was included in original credit upload please rescind the condition

05/08/2019:  Received attestation no affiliates.  Condition cleared.05/06/2019: Audit re-analyzed the loan documents, and has determined that the Affiliated Business Disclosure was NOT located within the file. No download was attached. Finding deemed non-material, loan will be graded a B for all agencies.

CLTV is lower than guideline maximum UW Guides maximum CLTV of 80%, loan qualified with CLTV of 70% DTI is lower than guideline maximum UW Guides maximum DTI of 43%, loan qualified with DTI of 30.30% Years in Primary Residence Borrower has resided in subject for 10 years

301150076

5edd5ccf-f0fb-45b2-a6cc-d7c9aa42b82d

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Compliance

Cleared

A

A

A

A

A

Compliance

Information required for CD 'Calculating Cash To Close' section not completed, or completed in error

The information in the Calculating Cash To Close section of the final Closing Disclosure indicates the Loan Estimate figure for Cash to Close of $XXXXX.  The most recent Loan Estimate dated XX/XX/XXXX indicates an amount of $XXXXX.   Provide re-disclosed CD and letter of explanation.

05/0/2019: please see attached loan estimate, please clear the condition

05/08/2019: Lender provided re-disclosed LE which matched the CD for calculating cash to close and provided verification of receipt of LE 4 days prior to consummation.  Condition cleared.

CLTV is lower than guideline maximum UW Guides maximum CLTV of 80%, loan qualified with CLTV of 70% DTI is lower than guideline maximum UW Guides maximum DTI of 43%, loan qualified with DTI of 30.30% Years in Primary Residence Borrower has resided in subject for 10 years

301150076

845f95d5-a16b-e911-bdd2-f4e9d4a75ba2

Underwriting Complete

QM/Non-HPML

QM/Non-HPML

Property

Cleared

A

A

A

A

A

Property

570 - Review Appraisal Missing

A CDA Report was not provided in the loan file.  CU Risk Score is 2.7.

05/07/2019: A CDA provided reflecting a value of $XXXXXX which is a 0% variance. Variance within acceptable tolerance.  Condition Cleared.

CLTV is lower than guideline maximum UW Guides maximum CLTV of 80%, loan qualified with CLTV of 70% DTI is lower than guideline maximum UW Guides maximum DTI of 43%, loan qualified with DTI of 30.30% Years in Primary Residence Borrower has resided in subject for 10 years

EX-99.4

Exhibit 99.4 - Schedule 4

Client Loan Number

Final Rating

Credit Rating

Compliance Rating

Property Rating

S&P Initial  Rating

S&P Final Rating

S&P Initial Credit Rating

S&P Final Credit Rating

S&P Initial Compliance Rating

S&P Final Compliance Rating

S&P Initial Property Rating

S&P Final Property Rating

Fitch Initial Rating

Fitch Final Rating

Fitch Initial Credit Rating

Fitch Final Credit Rating

Fitch Initial Compliance Rating

Fitch Final Compliance Rating

Fitch Initial Property Rating

Fitch Final Property Rating

Moodys Initial Rating

Moodys Final Rating

Moodys Initial Credit Rating

Moodys Final Credit Rating

Moodys Initial Compliance Rating

Moodys Final Compliance Rating

Moodys Initial Property Rating

Moodys Final Property Rating

Kroll Initial Rating

Kroll Final Rating

Kroll Initial Credit Rating

Kroll Final Credit Rating

Kroll Initial Compliance Rating

Kroll Final Compliance Rating

Kroll Initial Property Rating

Kroll Final Property Rating

DBRS Initial Rating

DBRS Final Rating

DBRS Initial Credit Rating

DBRS Final Credit Rating

DBRS Initial Compliance Rating

DBRS Final Compliance Rating

DBRS Initial Property Rating

DBRS Final Property Rating

301155663

1

1

1

1

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

301159179

1

1

1

1

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

301150504

1

1

1

1

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

301133752

1

1

1

1

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

301158639

1

1

1

1

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

301150076

2

2

1

1

D

B

D

B

D

A

D

A

D

B

D

B

D

A

D

A

D

B

D

B

D

A

D

A

D

B

D

B

D

A

D

A

D

B

D

B

D

A

D

A

301158540

1

1

1

1

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

301154813

1

1

1

1

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

301147129

1

1

1

1

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

D

A

D

A

A

A

A

A

EX-99.4

Exhibit 99.4 - Schedule 5

Loan Information

Origination Values

AVM Values

Desk Review Values

BPO Values

Field Review Values

2055 Values

Other Updated Values

Customer Loan ID

Original Loan Amount

Sale Price

Appraisal Value

Appraisal Date

Second Appraisal Value

Second Appraisal Date

Variance Amount

Variance Percent

Value Used for LTV

Estimated Value

Value Date

Variance Amount

Variance Percent

Confidence Score

Value

Value Date

Variance Amount

Variance Percent

Value

Value Date

Variance Amount

Variance Percent

Value

Value Date

Variance Amount

Variance Percent

Value

Value Date

Variance Amount

Variance Percent

Value Updated

Value Date

Report Type

Variance Amount

Variance Percent

Collateral Underwriter (CU) Risk Score

301155663

XXXX

XXXX

XXXX

XXXX

1.9

301159179

XXXX

XXXX

XXXX

XXXX

XXXX

1.5

301150504

XXXX

XXXX

XXXX

XXXX

1.4

301158639

XXXX

XXXX

XXXX

XXXX

2.4

301133752

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

0.00%

95

301158540

XXXX

XXXX

XXXX

XXXX

2

301150076

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

XXXX

0.00%

301154813

XXXX

XXXX

XXXX

XXXX

2

301147129

XXXX

XXXX

XXXX

XXXX

2.3