EX-99.1 2 exhibit991-1.htm EXHIBIT 99.1, SCHEDULE 1 - NARRATIVE

EXECUTIVE SUMMARY
THIRD PARTY DUE DILIGENCE REVIEW
Overview
Consolidated Analytics, Inc (“Consolidated Analytics”), a third-party due diligence provider, performed the review described below on behalf of its client, Artemis Management LLC. The review included a total of 242 residential mortgage loans, in connection with the securitization identified as MELLO 2021-1 (the “Securitization”). The review began on April 1, 2021, and concluded in April 30, 2021.
Scope of Review
Credit Review
Consolidated Analytics performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Client prior to review, and ensure the characteristics used by the underwriter are supported by the file documentation; and determine whether any loans outside of those guidelines contain legitimate and approved exceptions with compensating factors.
The Credit Review attempted to confirm the following:

a.
QM or ATR Validation / Review of 8 Key Underwriting Factors

i.
Income / Assets

Validate borrower(s) monthly gross income

Validate funds required to close, required reserves

Review file documentation for required level of income and asset verifications

ii.
Employment Status

Review file documentation for required level of employment

iii.
Monthly Mortgage Payment

Confirm program, qualifying rate, terms

iv.
Simultaneous Loans

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

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

Validate subject loan monthly payment (PITI) and associated obligations

vi.
Debts / Obligations

Validate monthly recurring liabilities

vii.
DTI and/or Residual Income

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

Documentation meets Appendix Q requirements for QM Loans

viii.
Credit History

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

Determine representative credit score from credit report

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

c.
Review borrower's occupancy

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



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

f.
Confirm that Final 1003 is sufficiently completed

g.
Provide Audit 1008 with accurate data based on file documentation

h.
Confirm Loan Approval conditions were met

i.
Review condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any red flags that may deem condominium project ineligible
Compliance Review
Consolidated Analytics performed a “Compliance Review” to determine, as applicable, to the extent possible and subject to the caveats below, whether the loan complies with applicable regulatory requirements as noted blow, each as amended, restated and/or replaced from time to time.  The Compliance Review included the following:


a.
Recalculation of APR and Finance Charge

b.
Testing of:

i.
Federal High Cost Mortgage provisions

ii.
Federal Higher Priced Mortgage Loans provisions

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


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

i.
Right to Receive Copy of Appraisal


d.
National Flood Insurance Program (NFIP) Review:

i.
Adherence to flood insurance coverage

ii.
Identification of flood zones

iii.
Evidence of adequate coverage amounts


e.
Fair Credit Reporting Act (FCRA)

f.
Home Mortgage Disclosure Act (HMDA)

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

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

i.
Review closing documents to ensure that the Mortgage Loan information is complete, accurate, and consistent with other documents; Confirm collateral documents have been recorded or sent for recording
The Compliance Review did not include any federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above.  Furthermore, the findings reached by Consolidated Analytics are dependent upon its receiving complete and accurate data regarding the loans from loan originators and other third parties upon which Consolidated Analytics is relying in reaching such findings.
Valuation Review
 Consolidated Analytics performed a “Valuation Review,” which included the following:

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



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

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

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

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

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

g.
Review appraisal to ensure all required documents were included.

h.
Review location map provided within the appraisal for external obsolescence.

i.
Ensure highest and best use and zoning complies with guidelines.

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

k.
Ensure subject property does not suffer any functional obsolescence.

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

m.
For loans with a PIW present in the loan file, 303 loans in total, original appraised values were provided by the client. A retroactive 2055 or documentation to substantiate the origination values as provided by the client was not present at the time of the review.

Consolidated Analytics applied a cascade methodology to determine if the original appraised value was reasonably supported when compared to an independent third-party valuation product.
For loans reviewed in a post-close valuation review scenario (242 loans in total):
98 loans had an Automated Valuation model which was performed by Collateral Analytics. Consolidated Analytics has independent access to the Desktop Reviews ordered by the Aggregator.
103 loans had Desktop Reviews which were performed by Consolidated Analytics (103 CCAs).
If a loan with a Desktop Review fell outside of a -10% tolerance or was inconclusive, then a Field Review, a Broker Price Opinion (BPO) along with a Reconciliation of the values or a 2nd Appraisal was completed.
0 loans had a Field Review of which zero Field Reviews did not support the value.
Product totals may not sum due to multiple products for each loan.
TAPE INTEGRITY REVIEW RESULTS SUMMARY
Of the 95 mortgage loans reviewed, one unique mortgage loans (by loan count) had a total of one different tape discrepancies across one data fields (some mortgage loans may have had more than one). A blank or zero value on the data tape when an actual value was captured by Consolidated Analytics was not treated as a data variance.
Fields Reviewed
 
Discrepancy Count
 
Percentage
 
Borrower_Last_Name
 
 
1
 
100%
 
Total Discrepancies:
 
1
 
100%
 


Summary of Results
OVERALL RESULTS SUMMARY
After giving consideration to the grading criteria of the relevant NRSROs, 100% of the loans received a grade “B” or higher 93.68% of the pool receiving an Overall “A” grade.

Final Loan Grades

Overall Loan Results:
 
 
Event Grade
 
Loan Count
 
Original Principal Balance
 
Percent of Sample
 
Event  Grade A
 
89
 
$45,033,321
 
93.68%
 
Event  Grade B
 
6
 
$3,678,489
 
6.32%
 
Event  Grade C
 
0
 
$0.00
 
0%
 
Event  Grade D
 
0
 
$0.00
 
0%
 
Total Sample
 
95
 
$48,711,810
 
100%
 

Credit Results:
 
Event Grade
 
Loan Count
 
Percent of Sample
 
Event  Grade A
 
92
 
96.84%
 
Event  Grade B
 
3
 
3.16%
 
Event  Grade C
 
0
 
0%
 
Event  Grade D
 
0
 
0%
 
Total Sample
 
95
 
100%
 

Compliance Results:
 
Event Grade
 
Loan Count
 
Percent of Sample
 
Event  Grade A
 
92
 
96.84%
 
Event  Grade B
 
3
 
3.16%
 



Event  Grade C
 
0
 
0%
 
Event  Grade D
 
0
 
0%
 
Total Sample
 
95
 
100%
 

Valuation Results:
 
Event Grade
 
Loan Count
 
Percent of Sample
 
Event  Grade A
 
95
 
100%
 
Event  Grade B
 
0
 
0%
 
Event  Grade C
 
0
 
0%
 
Event  Grade D
 
0
 
0%
 
Total Sample
 
95
 
100%
 

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

Exception Type
 
Exception Level Grade
 
Exception Category
 
Total
 
       
Credit
 
A
 
Appraisal date is greater than 120 days from Origination date.
 
7
 
   
Asset Documents are Incomplete
 
2
 
   
AUS is Partial
 
1
 



   
Balance Sheet Does Not Meet Guidelines
 
1
 
   
Borrower 2 is missing signed 4506t.
 
1
 
   
Borrower Asset Verification is Missing
 
2
 
   
Borrower Credit Report is Missing
 
1
 
   
Borrower Employment Verification does not meet guidelines
 
7
 
   
Borrower Income Verification does not match Approval
 
4
 
   
Borrower Liabilities Verification Indicator is Partial
 
20
 
   
Borrower Liabilities Verificiation Indicator is Missing
 
1
 
   
Borrower residency documentation not provided or issue with documentation
 
1
 
   
CLTV Exceeds the AUS Maximum Allowable
 
1
 
   
CoBorrower Asset Verification is Missing
 
1
 
   
CoBorrower Credit Report is Missing
 
1
 
   
CoBorrower Employment Verification does not meet guidelines
 
4
 
   
CoBorrower Income Verification does not match Approval
 
2
 
   
CoBorrower Liabiliities Verified Indicator is Missing
 
1
 
   
Co-Borrower residency documentation not provided or issue with documentation
 
1
 
   
DTI Exceeds AUS Maximum Allowable
 
5
 
   
Executed HELOC closure letter not provided.
 
1
 
   
Final Loan Application is Missing
 
3
 
   
Flood Certificate is Missing
 
1
 
   
Flood Certificate is Partial
 
2
 
   
HAZARD INSURANCE CERTIFICATE MISSING
 
1
 
   
Hazard Insurance Coverage is Not Sufficient.
 
2
 
   
Hazard Insurance Effective Date is after the Note Date
 
1
 
   
HMDA Data Tape Not Provided
 
1
 



   
Housing history does not meet guidelines
 
1
 
   
Liquid Reserves (Dollar Amount) are less than AUS Minimum Required
 
4
 
   
LTV Exceeds AUS Maximum Allowable
 
1
 
   
Note Document Indicator is Missing
 
1
 
   
Number of Mortgage Properties Exceeds Max Allowable Per Guidelines
 
1
 
   
Property is located in a FEMA disaster area
 
28
 
   
Servicing Comments are Missing
 
1
 
   
Signed 4506t is missing
 
2
 
   
Transmittal Summary is Missing
 
1
 
   
Trust Documentation Missing or Incomplete
 
1
 
   
Total Credit Grade (A) Exceptions:
 
117
 
       
Credit
 
B
 
DTI Exceeds AUS Maximum Allowable
 
2
 
   
FICO is less than the AUS Minimum Required
 
1
 
   
Total Credit Grade (B) Exceptions:
 
3
 
       
Compliance
 
A
 
ATR/QM Status is Pending
 
1
 
   
Evidence of Rate Lock Not Provided
 
1
 
   
Intent to Proceed is Missing
 
1
 
   
Security Instrument Indicator is Missing
 
3
 
   
Total Compliance Grade (A) Exceptions:
 
6
 
       
Compliance
 
B
 
Charges That Cannot Increase Test
 
3
 
   
Consummation or Reimbursement Date Validation Test
 
3
 
   
Initial Closing Disclosure Delivery Date Test
 
1
 
   
Lender Credits That Cannot Decrease Test
 
1
 



   
Reimbursement Amount Test
 
2
 
   
TRID Disclosure Delivery and Receipt Date Validation Test
 
1
 
   
TRID Post-Consummation Reason for Redisclosure Validation Test
 
1
 
   
Total Compliance Grade (B ) Exceptions:
 
12
 
       
Valuation
 
A
 
Informational Only - Property Inspection Waiver used at origination.
 
24
 
   
Origination Appraisal is Missing
 
1
 
   
Origination Appraisal is Partial
 
2
 
   
Third Party AVM to appraised value exceeds 10% allowable variance
 
6
 
   
Third Party Desk Review variance to appraised value exceeds 10%
 
1
 
   
Third Party Valuation Product not Provided
 
79
 
   
Third Party Valuation Product Not Provided and FHLMC Collateral Rep & Warrant Relief is Not Eligible or Unavailable.
 
20
 
   
Third Party Valuation Product not Provided.
 
1
 
   
Total Valuations Grade (A) Exceptions:
 
134
 
       





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

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




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

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