EX-99.3 17 ex99-3s2.htm SCHEDULE 2 - COMPLIANCE REPORT

 

 

Chase Home Lending Mortgage Trust 2024-RPL2 ABS-15G

Exhibit 99.3 - Schedule 2

 

Grade Summary
 
Standard and Poor's Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 13 12 14 12
B 0 469 0 468
C 1 9 0 10
D 0 10 0 10
Total 14 500 14 500
 
Fitch Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 13 12 14 12
B 0 468 0 468
C 1 10 0 10
D 0 10 0 10
Total 14 500 14 500
 
DBRS Rating Agency Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 13 12 14 12
B 0 469 0 468
C 1 9 0 10
D 0 10 0 10
Total 14 500 14 500
 
Moodys Rating Agency Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 13 12 14 12
B 0 468 0 468
C 1 10 0 10
D 0 10 0 10
Total 14 500 14 500
 
Kroll Rating Agency Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 13 12 14 12
B 0 469 0 468
C 1 9 0 10
D 0 10 0 10
Total 14 500 14 500

 

 
 
                                                   
Loan Level Exception - Disposition                                                    
                                                     
AMC Loan ID Customer Loan ID Alternate Loan ID Seller Loan ID Borrower Name Original Loan Amount State Note Date Occupancy Purpose QM Status Overall Grade Credit Exceptions Credit Exception Information Credit Exception Comments Property Exceptions Property Exception Information Property Exception Comments Compliance Grade Compliance Exceptions Compliance Exception Information Compliance Exception Comments Compliance Comp Factors Compensating Factors Subject to High Cost - Unable to Test Disposition 2 Fitch Final Rating Moodys Final Rating DBRS Final Rating SP Final Rating Kroll Final Rating
XXXX   3158496239   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] State Compliance - Connecticut Prepayment Penalty Test: Connecticut Prepayment Penalty: A prepayment penalty is not permissible under the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date ofXX/XX/XXXX 12:00:00 AM.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL itemization did not disclose Subordination recording fee $15 and Title Courier fee $30 as prepaid finance charge BUYER - GENERAL COMMENT (2024-04-10): Cited prohibition is applicable to a mortgage broker. Prepayment penalty is payable to XXXX which is the lender per Sec. 36a-485. (Formerly Sec. 36-440). Definitions. (19).
REVIEWER - GENERAL COMMENT (2024-04-16): The exemption from the prepayment penalty restriction established in the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act is not a blanket exemption for all mortgage brokers. The mortgage broker or mortgage lender must meet one of the exemptions from licensure established in Section 36a-487 of the Act.  While XXXXX meets exemption under 36a-487(a)(1), it is not clear if the lender in the request meet any of the exemptions listed in this section. Please provide information about how each of the lenders meets ones of the exemptions listed in Section 36a-487. Exception remains.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158496242   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   3             3 [3] Anti-Predatory Violation - Federal HOEPA Ability to Repay Reliable Documentation: Truth in Lending Act (HOEPA): Borrower’s ability to repay not verified with reliable documentation.
[3] Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee): Truth in Lending Act (HOEPA): Required Statement was not provided to purchaser or assignee for loan that was sold or assigned. (Note: This notice only applies when selling or assigning a HOEPA loan and may not be found in the file for loans that have not been previously sold)
[3] Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided): Truth in Lending Act (HOEPA):  HOEPA disclosure was not provided to the Borrower
[3] Federal Compliance - (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees): Truth in Lending Act (HOEPA): Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of X.XX% of the Federal Total Loan Amount and $XXXX XXXX. Points and Fees of $XXXX on a Federal Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-03): Appeal:  The Federal Total Loan amount would not include the $180 Doc Prep fee which is not a prepaid finance charge under reg z and therefore the 8% threshold is XXXX with a points and fees total of XXXX.
REVIEWER - GENERAL COMMENT (2024-04-04): Exception remains. The $180 doc prep fee is paid to the lender, so it is included as part of the total loan amount calculation.  When the doc prep fee is missing payee on HUD, our default is to test it as paid to lender. However, in this file, the Itemization of Amount Financed confirms the doc prep fee payee is the lender.
Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.  Effective 1/10/2014: Creditors may be held liable to the consumer for civil liability of $4,000, in the case of an individual transaction, or the lesser of $1,000,000 or 1% of the creditor's net worth in the case of a class action, as well as actual damages court costs and attorneys' fees.

Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.  Effective 1/10/2014: Creditors may be held liable to the consumer for civil liability of $4,000, in the case of an individual transaction, or the lesser of $1,000,000 or 1% of the creditor's net worth in the case of a class action, as well as actual damages court costs and attorneys' fees.

Federal Compliance - (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    HC - High Cost C C C C C
XXXX   3158482734   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.           - B B B B B
XXXX   3158496250   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.           - B B B B B
XXXX   3158482754   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.
BUYER - GENERAL COMMENT (2024-04-05): initial 1003
REVIEWER - GENERAL COMMENT (2024-04-08): No action, comment initial 1003 on a final 1003 exception.
      2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] State Compliance - Ohio Prepayment Penalty: Ohio Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 1% of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
  BUYER - GENERAL COMMENT (2024-04-05): initial 1003
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.
BUYER - GENERAL COMMENT (2024-04-05): ABA
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.
Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158496251   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
  BUYER - GENERAL COMMENT (2024-04-15): Please see signed TIL page 75 DO551 also please see RTC page 234 D0038 signed XX/XX/XXXX Borrower signed on a Saturday which is a working day and 3 days midnight on Wednesday XX/XX/XXXX. I have enclosed a calendar for your verification
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, missing disbursement date from loan file to determine timing.
Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.     - B B B B B
XXXX   3158496253   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - West Virginia Prepay Penalty: West Virginia Prepayment Penalty: Loan prepay term of 60 months exceeds state maximum of 36 months.   Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158482765   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496255   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] Anti-Predatory Violation - (Fed High Cost Provision) Federal High-Cost Mortgage Loan (ATR - FIR Not Used on ARM Loan): Truth in Lending Act (HOEPA):  Fully-indexed rate not used to determine ability to repay on ARM loan.
[3] Anti-Predatory Violation - Federal HOEPA Ability to Repay Reliable Documentation: Truth in Lending Act (HOEPA): Borrower’s ability to repay not verified with reliable documentation.
[3] Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee): Truth in Lending Act (HOEPA): Required Statement was not provided to purchaser or assignee for loan that was sold or assigned. (Note: This notice only applies when selling or assigning a HOEPA loan and may not be found in the file for loans that have not been previously sold)
[3] Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided): Truth in Lending Act (HOEPA):  HOEPA disclosure was not provided to the Borrower
[3] Federal Compliance - (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees): Truth in Lending Act (HOEPA): Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of X.XX% of the Federal Total Loan Amount and $XXXX XXXX. Points and Fees of $XXXX on a Federal Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] 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.
[2] State Compliance - Ohio Prepayment Penalty: Ohio Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 1% of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure is due lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.
  Anti-Predatory Violation - (Fed High Cost Provision) Federal High-Cost Mortgage Loan (ATR - FIR Not Used on ARM Loan): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.  Effective 1/10/2014: Creditors may be held liable to the consumer for civil liability of $4,000, in the case of an individual transaction, or the lesser of $1,000,000 or 1% of the creditor's net worth in the case of a class action, as well as actual damages court costs and attorneys' fees.

Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.  Effective 1/10/2014: Creditors may be held liable to the consumer for civil liability of $4,000, in the case of an individual transaction, or the lesser of $1,000,000 or 1% of the creditor's net worth in the case of a class action, as well as actual damages court costs and attorneys' fees.

Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.  Effective 1/10/2014: Creditors may be held liable to the consumer for civil liability of $4,000, in the case of an individual transaction, or the lesser of $1,000,000 or 1% of the creditor's net worth in the case of a class action, as well as actual damages court costs and attorneys' fees.

Federal Compliance - (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.

Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    HC - High Cost C C C C C
XXXX   3158482778   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Insurance Documentation - Missing Document: Mortgage Insurance Certificate (MIC) not provided   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.
BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024 Unable to locate Mortgage Insurance Certificate. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action
      2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
  BUYER - GENERAL COMMENT (2024-04-04): 4/4/2024 Unable to locate ARM loan program disclosure. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action
BUYER - GENERAL COMMENT (2024-04-04): 4/4/2024 Unable to locate Charm Booklet. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action
BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024 Unable to locate initial GFE. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action
BUYER - GENERAL COMMENT (2024-04-04): 4/4/2024 Unable to locate initial lender 1003. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action
BUYER - GENERAL COMMENT (2024-04-04): 4.4.24  Unable to locate Final TIL. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496260   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: The Flood Zone was determined on XX/XX/XXXX as per Flood Certificate hence the Lender provided Notice to Borrower for property being in flood hazard zone on XX/XX/XXXX which is less than 10 business days from the Note date.
  Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158482793   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] State Compliance - Kansas Prepayment Penalty: Kansas Prepayment Penalty:  Loan contains an impermissible prepayment penalty of greater than 6 months.  Prepay language states prepay will not exceed maximum permitted by applicable law.           - B B B B B
XXXX   3158482809   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Note Interest Accrual Start Date of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Oregon Prepayment Penalty Max Prepay: Oregon Prepayment Penalty: Loan agreement or Note does not clearly state the maximum prepayment penalty applicable to each year of the loan.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496271   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496275   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Ohio Prepayment Penalty: Ohio Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 1% of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496277   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Louisiana Prepayment Penalty: Louisiana Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% (in Years 1-5).  Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%,   which exceeds the max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-11): Please see page 32 D0720 Approval shows purpose Construction Perm also look at Appraisal Page 999 D0650 shows current owner XXXX XXXX. Right to cancel documentation does not apply
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, It is unclear whether or not the previous loan included permanent financing. There is not enough information to determine whether the previous loan was construction-only or construction-permanent. Based on SitusAMC’s discussion with outside counsel, if the subject transaction refinanced permanent financing, it would be considered a standard refinance as opposed to a residential mortgage transaction and would therefore be subject to rescission. If the borrower was not obligated on permanent financing prior to subject transaction, please provide Note/HUD from prior transaction(s) or other evidence that loan(s) being satisfied were the initial construction only and that the borrower was not obligated on an existing permanent phase financing. Otherwise, a refinance of an existing permanent phase Note would make the subject transaction a refinance subject to rescission. Also just wanted to point out this exception is an EV-2.
Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.     - B B B B B
XXXX   3158496279   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158482850   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List): Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.
[2] State Compliance - Michigan Prepayment Penalty: Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.
BUYER - GENERAL COMMENT (2024-04-05): 4-5-24 APPEAL, Please check rounding for FIR.  Per note it is nearest .125 but LAS is showing FIR in Finance Charge chart as X.XX which corresponds to .001.  /DE
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains, rounding per Note is 0.125% and missing index utilized for disclosed TIL.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158482859   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty): Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 60 days interest on the unpaid principal balance.
[2] State Compliance - Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 2% of the unpaid principal balance of the loan.: Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
[2] 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).
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-04): 04-04-2024  Appeal.  Please clarify nature of exception. Subject RTC is dated Monday XX/XX/XXXX as transaction date and Thursday XX/XX/XXXX as close of rescsission.  HUD1 shows funding date on Friday XX/XX/XXXX. The mortgage is notarized on the transaction date as XX/XX/XXXX. All dates appear proper. Please clarify details of conflict.  MC
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, Notary date on recorded security instrument is 0XX/XX/XXXX.
BUYER - GENERAL COMMENT (2024-04-04): 04-04-2024  Appeal.  Please clarify nature of exception. Subject RTC is dated Monday XX/XX/XXXX as transaction date and Thursday XX/XX/XXXX as close of rescsission.  HUD1 shows funding date on Friday XX/XX/XXXX. The mortgage is notarized on the transaction date as XX/XX/XXXX. All dates appear proper. Please clarify details of conflict.  MC
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, Notary date on recorded security instrument is 0XX/XX/XXXX.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

State Compliance - Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty): Assignee liability is unclear.  Purchasers and assignees of Minnesota mortgage loans would not appear to be liable for violations of the Act. However, effective 8/1/07, although there does not appear to be any explicit assignee liability, because a new private right of action permits a court to award statutory damages equal to the amount of all lender fees included in the amount of the principal of the residential mortgage loan, there is the potential that secondary market participants may be adversely affected.

State Compliance - Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 2% of the unpaid principal balance of the loan.: Assignee liability is unclear.  Purchasers and assignees of Minnesota mortgage loans would not appear to be liable for violations of the Act. However, effective 8/1/07, although there does not appear to be any explicit assignee liability, because a new private right of action permits a court to award statutory damages equal to the amount of all lender fees included in the amount of the principal of the residential mortgage loan, there is the potential that secondary market participants may be adversely affected.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158482860   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] State Compliance - Illinois Late Charge Percent Testing: Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-08): 4/8/2024 Unable to locate ARM loan program disclosure after reviewing EIV and Acuity. JF
REVIEWER - GENERAL COMMENT (2024-04-09): No action
BUYER - GENERAL COMMENT (2024-04-08): 4/8/2024 Unable to locate Consumer Handbook on ARM, CHARM Booklet, provided to borrower within 3 days of application after reviewing EIV and Acuity. JF
REVIEWER - GENERAL COMMENT (2024-04-09): No action
BUYER - GENERAL COMMENT (2024-04-08): 4/8/2024 Unable to locate initial GFE after reviewing EIV and Acuity. JF
REVIEWER - GENERAL COMMENT (2024-04-09): no action
BUYER - GENERAL COMMENT (2024-04-08): 4/8/2024 Unable to locate ABA disclosure dated within 3 business days of application after reviewing EIV and Acuity. JF
REVIEWER - GENERAL COMMENT (2024-04-09): No action
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158482869   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
  BUYER - GENERAL COMMENT (2024-04-04): 4/4/2024: Appeal: Please reference page 1272 Doc Code 0217 and page 6524 / 7487 no Doc Code for the Welcome Letter pages 1 and 2 dated XX/XX/XXXX which reflects the ABA disclosure was an enclosed disclosure. Also, pages 1265 & 1266 Doc Code 0665 reflects the ABA disclosure with the date on page 2. ABA date of XX/XX/XXXX is with 3 days Application Date XX/XX/XXXX. LM
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, missing affiliated business disclosure from XX/XX/XXXX.
Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158482875   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158482880   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158482883   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.           - B B B B B
XXXX   3158482893   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496298   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is.X.XX%.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158482900   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.
    - B B B B B
XXXX   3158482907   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.
    - B B B B B
XXXX   3158482910   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] State Compliance - Georgia Home Loan (Late Charge): Georgia Home Loan:  Mortgage loan contains an impermissible late charge of greater than 5.0% or a grace period of less than ten (10) days.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure unable to find due to itemizaton is missing. BUYER - GENERAL COMMENT (2024-04-05): Appeal: Please check amount of prepaid interest included in your finance charge calculation.  Loan disbursed on XX/XX/XXXX and three days per diem was collected through XX/XX/XXXX.
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains.  Interest captured per HUD i/a/o $XXX.
State Compliance - Georgia Home Loan (Late Charge): Assignee Liability:  Any person who purchases, is assigned or otherwise becomes a holder of a high cost home loan will be subject to all affirmative claims and defenses that the borrower could assert against the creditor of the high cost home loan, including the right of rescission which applies regardless of whether the safe harbor provision is met.  In an action brought by a borrower against an assignee: (i) the borrower may only assert the action individually and any relief granted may not exceed the sum of the amount of all remaining indebtedness of the borrower and reasonable attorneys' fees in the individual action; (ii) the borrower may only assert a claim of a violation of the flipping and prohibited high cost home loan provisions in response to the holder's notice of acceleration or foreclosure notice; and (iii) the borrower must bring the action within one year from the date of the occurrence of the violation, except in defense by recoupment or setoff.

Note:  Loans originated between 10/1/02 and 3/6/03 are subject to the Original GAFLA.  Rating Agencies will not rate GA loans originated during this time period.

Late Charge:
For loans subject to Original GAFLA (10/1/2002 to 3/6/2003), material violation.

For loans not subject to Original GAFLA (on or after 3/7/03), late charge violations could be downgraded to an EV2 depending on statute of limitations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158482915   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List): Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.
[2] State Compliance - Michigan Prepayment Penalty: Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.
    - B B B B B
XXXX   3158482929   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Insurance Documentation - Flood Insurance Error: Insurance premium was not provided.
[2] Insurance Documentation - Missing Document: Flood Insurance Policy not provided
  REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.
REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.
      2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.
    - B B B B B
XXXX   3158482937   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158482941   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158482942   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Lien - Missing evidence of lien position on Other Financing.: Lien Position: 2   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.
BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024: Appeal. Please identify the other financing referenced on the Exception Notes. LL
REVIEWER - GENERAL COMMENT (2024-04-08): Per the 1003 in the file Details of Transaction includes Subordinate Financing i/a/o $XXXX.
BUYER - GENERAL COMMENT (2024-04-17): Concerning lien position for subject loan please see Title Policy pages 743-751 D0537 insuring us in 1st Position. Title company would handle any subordination however title commitment shows no other liens. Credit Report page 629-631 D0066 shows XXXX opened XX/XX/XXXX reporting as revolving and included in borrower's DTI. Your file also included a QCD page 55 D0003 from XXXX to XXXX and XXXX. In trailing docs page 2805 there is a Lexis Nexis verifing release of  multiple loans from XXXX dated XX/XX/XXXX and XX/XX/XXXX.
REVIEWER - GENERAL COMMENT (2024-04-19): Exception remains, final 1003 and approval list subordinate financing but missing Note and terms of subordinate.
      2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
  Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158482945   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   1             1             - A A A A A
XXXX   3158482946   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.
    - B B B B B
XXXX   3158496309   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496313   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158482967   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Captured as per source document
BUYER - GENERAL COMMENT (2024-04-04): Please see page D0591 for application date of XX/XX/XXXX.
REVIEWER - GENERAL COMMENT (2024-04-04): Exception remains, missing initial lenders 1003. Alt application date captured as XX/XX/XXXX
BUYER - GENERAL COMMENT (2024-04-03): 4.3.24 Appeal attached Flood Zone Timing Notification Special Hazard in AMC p129of2003 -D 0400 original disclosures mailed to borrower XX/XX/XXXX-XX/XX/XXXX-and signed XX/XX/XXXX kindly review rescind.gs.
REVIEWER - GENERAL COMMENT (2024-04-04): Exception remains, disclosure stamped 0XX/XX/XXXX is not the Special Flood Hazards disclosure associated with the review.
BUYER - GENERAL COMMENT (2024-04-05): 04.05.24 Appeal attached Notice of Special Flood dated XX/XX/XXXX and XX/XX/XXXX kindly advise.gs.
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remians, The final rule provides that delivery of notice must take place within a “reasonable time” before the completion of the transaction. What constitutes “reasonable” notice may vary according to the individual circumstances of a transaction. The preamble to the final rule states that the agencies generally continue to regard ten days as a “reasonable” time interval. However, in all cases an institution should bear in mind that a borrower should receive notice timely enough to ensure that borrower had opportunity to obtain flood insurance.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158482968   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing         - B B B B B
XXXX   3158482969   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158496315   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496320   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] State Compliance - Louisiana Prepayment Penalty: Louisiana Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% (in Years 1-5).  Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%,   which exceeds the max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
  Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496324   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List): Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-04): See 3rd paragraph on D0803. XXXX provided a number and link to HUD's list of Michigan counselors.
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, missing list of the nearest available housing counseling agencies approved by the United States Department of Housing and Urban Development.
      - B B B B B
XXXX   3158483003   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List): Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.
[2] State Compliance - Michigan Prepayment Penalty: Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
    State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.
    - B B B B B
XXXX   3158496328   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158496331   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Oregon Late Charge Grace Period Testing: Oregon Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Oregon Late Charge Percent Testing: Oregon Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] State Compliance - Oregon Prepayment Penalty Max Prepay: Oregon Prepayment Penalty: Loan agreement or Note does not clearly state the maximum prepayment penalty applicable to each year of the loan.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483013   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Insurance Documentation - Flood Insurance Error: Policy number is not provided.   BUYER - GENERAL COMMENT (2024-04-17): Flood Policy Number does show pending page 928 D0564 subject closed XX/XX/XXXX;  however please review HUD-1 page 265 D0016 line 904 premium of $XXX.XX paid out of closing to XXX same as policy and  the flood insurance is also set up for monthly escrow
REVIEWER - GENERAL COMMENT (2024-04-19): Exception remains, flood policy does not contain policy number.
      2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.
    - B B B B B
XXXX   3158483031   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Flood Certificate Error: Certificate Number was not provided.   BUYER - GENERAL COMMENT (2024-04-04): Flood Hazard Determination in file page D0824 showing property in flood zone X  along with map number and date.  Please confirm a certificate number is required as page two of the flood determination does not show a certificate number requirement.  Thanks.
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, missing flood determination certificate number from flood cert.
      2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158483032   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   1             1             - A A A A A
XXXX   3158483034   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing         - B B B B B
XXXX   3158483038   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158496338   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158483053   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158496347   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158496348   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Wisconsin Late Charge Amount Testing First Lien: Wisconsin Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] State Compliance - Wisconsin Late Charge Grace Period Testing > $25,000: Wisconsin Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Wisconsin Prepayment Penalty ARM Test: Wisconsin Prepayment Penalty:  Adjustable rate loan containing prepayment penalty did not provide disclosure stating that there are also loans available without prepayment penalties.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing         - B B B B B
XXXX   3158483081   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Missouri Late Charge Grace Period Testing: Missouri Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Missouri Prepayment Penalty: Missouri Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483083   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
  Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158496352   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Illinois Late Charge Percent Testing: Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496353   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Massachusetts Late Charge Grace Period Testing: Massachusetts Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Massachusetts Late Charge Percent Testing: Massachusetts Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 3%.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483097   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483102   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.
BUYER - GENERAL COMMENT (2024-04-08): 4/8/2024 Unable to locate FACT Credit Score Disclosure in Acuity or EIV. JF
REVIEWER - GENERAL COMMENT (2024-04-09): No action. Comment reflects not able to locate.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496360   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] Anti-Predatory Violation - Federal HOEPA Ability to Repay Reliable Documentation: Truth in Lending Act (HOEPA): Borrower’s ability to repay not verified with reliable documentation.
[3] Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee): Truth in Lending Act (HOEPA): Required Statement was not provided to purchaser or assignee for loan that was sold or assigned. (Note: This notice only applies when selling or assigning a HOEPA loan and may not be found in the file for loans that have not been previously sold)
[3] Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided): Truth in Lending Act (HOEPA):  HOEPA disclosure was not provided to the Borrower
[3] Federal Compliance - (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees): Truth in Lending Act (HOEPA): Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of X.XX% of the Federal Total Loan Amount and $XXXX XXXX. Points and Fees of $XXXX on a Federal Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Disclosed Note P&I payment does not equal calculated P&I payment: Disclosed Note P&I payment does not equal calculated P&I payment.  Note P&I of $XXXX does not match calculated P&I of $XXXX. Calculated P&I was used for the APR calculation and compliance testing.
[2] State Compliance - Louisiana Late Charge Percent Testing: Louisiana Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] State Compliance - Louisiana Prepayment Penalty: Louisiana Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% (in Years 1-5).  Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%,   which exceeds the max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] 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
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
BUYER - GENERAL COMMENT (2024-04-09): Please see final TIL dated XX/XX/XXXX by the borrower which verifies exact date of closing
REVIEWER - GENERAL COMMENT (2024-04-09): Unable to conclusively determine date of consummation. Missing Security Instrument Notary Date. Exception remains.
Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.  Effective 1/10/2014: Creditors may be held liable to the consumer for civil liability of $4,000, in the case of an individual transaction, or the lesser of $1,000,000 or 1% of the creditor's net worth in the case of a class action, as well as actual damages court costs and attorneys' fees.

Anti-Predatory Violation - (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.  Effective 1/10/2014: Creditors may be held liable to the consumer for civil liability of $4,000, in the case of an individual transaction, or the lesser of $1,000,000 or 1% of the creditor's net worth in the case of a class action, as well as actual damages court costs and attorneys' fees.

Federal Compliance - (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees): Assignee Liability:  A purchaser or assignee of a HOEPA loan is subject to all claims and defenses that the consumer could assert against the original creditor. This potential liability is limited to the sum of (a) all remaining indebtedness (including principal) and (b) the total amount paid by the borrower (including principal and interest), whether or not paid prior to the transfer of the loan to the assignee.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    HC - High Cost C C C C C
XXXX   3158483112   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024 Unable to locate the initial ARM Disclosure after reviewing Acuity and EIV. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action. Unable to locate per response comments.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.
    - B B B B B
XXXX   3158496364   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
  BUYER - GENERAL COMMENT (2024-04-04): 04/04/2024 Appeal: Please see the uploaded document (exception id 30275010)  with confirms the application date of XX/XX/XXXX which is the date the ARM Disclosure was sent to the borrower. CK
REVIEWER - GENERAL COMMENT (2024-04-05): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-04): 04/04/2024 Appeal: Please see the uploaded document (exception id 30275010)  with confirms the application date of XX/XX/XXXX which is the date the CHARM Booklet was sent to the borrower. CK
REVIEWER - GENERAL COMMENT (2024-04-05): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-04): 4/4/2024 Appeal: Please find attached verification for the application date of 0XX/XX/XXXX. CK
REVIEWER - GENERAL COMMENT (2024-04-05): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-04): 4/04/2024 Appeal: Please see the uploaded validation (exception id 30275010)  which reflects the application date of 0XX/XX/XXXX. D0229 – ABA dated 0XX/XX/XXXX. CK
REVIEWER - GENERAL COMMENT (2024-04-05): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158483120   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List): Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.
[2] State Compliance - Michigan Prepayment Penalty: Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.
    - B B B B B
XXXX   3158483135   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing BUYER - GENERAL COMMENT (2024-04-08): 4/8/2024 Unable to locate FACTA Credit Score Disclosure in EIV or Acuity. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action. Comments reflect unable to locate.
Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158483139   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Missouri Late Charge Grace Period Testing: Missouri Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Missouri Prepayment Penalty: Missouri Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-08): 4/8/2024 Unable to locate FACTA Credit Score Disclosure.
REVIEWER - GENERAL COMMENT (2024-04-08): No action. Comment advises unable to locate.
Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158496374   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483146   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
  Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496377   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material: Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. REVIEWER - GENERAL COMMENT (2024-04-09): Exempt from federal and state high cost testing.  Exception regraded to EV2-B.       - B B B B B
XXXX   3158483158   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496380   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158483175   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.
  Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483180   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Maryland Interest and Usury Prepayment Penalty: Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] State Compliance - Maryland Late Charge Grace Period Testing: Maryland Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Maryland Late Charge Percent and Amount Testing: Maryland Late Charge: Note late charge of X.XX%/$XXXX exceeds state maximum of 5% or $2, whichever is greater.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158483181   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Disclosed Note P&I payment does not equal calculated P&I payment: Disclosed Note P&I payment does not equal calculated P&I payment.  Note P&I of $XXXX does not match calculated P&I of $XXXX. Calculated P&I was used for the APR calculation and compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158483183   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483184   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158496388   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List): Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.
[2] State Compliance - Michigan Prepayment Penalty: Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided): Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided: Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.
    - B B B B B
XXXX   3158483193   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496392   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158483203   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158496396   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158483209   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158483210   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158496399   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing         - B B B B B
XXXX   3158496401   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Maryland Interest and Usury Prepayment Penalty: Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] State Compliance - Maryland Late Charge Grace Period Testing: Maryland Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Maryland Late Charge Percent and Amount Testing: Maryland Late Charge: Note late charge of X.XX%/$XXXX exceeds state maximum of 5% or $2, whichever is greater.
          - B B B B B
XXXX   3158496402   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Virginia Late Charge Percent Testing: Virginia Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496404   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Illinois Late Charge Percent Testing: Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158496406   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.
BUYER - GENERAL COMMENT (2024-04-09): Appeal:  The $150 difference in finance charges appears to be the vendor including the $150 signing fee, but it appears a signing fee listed in the 1100 series of the HUD-1 is not considered a finance charge.
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains, While notary fees are excluded from finance charges and APR calculations, only the notary fee portion is excludable but signing fees and mobile services are not and these would be included as finance charges. Commentary to Regulation Z 1026.4(e)(1) provides:
1. Notary fees. In order for a notary fee to be excluded under §1026.4(e)(1), all of the following conditions must be met:
2. The document to be notarized is one used to perfect, release, or continue a security interest.
3. The document is required by law to be notarized.
iii. A notary is considered a public official under applicable law.
1. The amount of the fee is set or authorized by law.
If evidence can be provided that any portion of the Signing Fee was for notarizing documents as detailed above, that portion can be excluded from finance charges.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158483226   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158483230   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.
BUYER - GENERAL COMMENT (2024-04-18): Unable to account for variance in LAS Report using the same PPFCs. XXXX recalculation did not result in a variance of the PPFCs. The total disclosed pre-paids was $XXXX (Loan Amount $XXXX - TIL Amount Financed $XXXX). The PPFC's totaling $XXXX includes: Loan Origination Fee $2,500 + Tax Service Fee $84 + Processing Fee $500 + UW Fee $300 + Flood Cert $5 + Broker Fee $495 + Processing Fee $500 + Courier/Messenger Fee $20 – Prepaid Interest $128.05 + Settlement Fee $450 + Title Courier $50 + Wire Fee $35 + Loan Tie-in Fee $100 + Sub-Escrow Fee $150 + Check Processing Fee $40 + Recording Fee $69 + Title Courier Fee $10 + Wire $10.
REVIEWER - GENERAL COMMENT (2024-04-19): Exception remains, Missing itemization of amount financed to determine what fees were disclosed on the TIL as prepaid finance charges.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158483236   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483237   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Missouri Late Charge Grace Period Testing: Missouri Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Missouri Prepayment Penalty: Missouri Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496410   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to verify finance charge under disclosure due to missing TIL Itemization.
BUYER - GENERAL COMMENT (2024-04-04): 4/4/24-Appeal : Doc Signing ($425) aka Notary Fee is not a PPFC. Please recalculate. TC
REVIEWER - GENERAL COMMENT (2024-04-05): While notary fees are excluded from finance charges and APR calculations, only the notary fee portion is excludable but signing fees and mobile services are not and these would be included as finance charges. Commentary to Regulation Z 1026.4(e)(1) provides:
1. Notary fees. In order for a notary fee to be excluded under §1026.4(e)(1), all of the following conditions must be met:
2. The document to be notarized is one used to perfect, release, or continue a security interest.
3. The document is required by law to be notarized.iii. A notary is considered a public official under applicable law.
1. The amount of the fee is set or authorized by law.
If the fee disclosed represents a notary and signing fee lumped together, the total would be considered a finance charge unless it can be demonstrated which portion was allocated for which service. If documentation can be provided identifying which portion of charge was for notarizing documents, we can exclude this portion from finance charges.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158483246   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158496413   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Illinois Late Charge Percent Testing: Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158483267   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Pennsylvania First Lien Late Charge Grace Period Testing: Pennsylvania Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483272   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Wisconsin Late Charge Amount Testing First Lien: Wisconsin Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] State Compliance - Wisconsin Late Charge Grace Period Testing > $25,000: Wisconsin Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Wisconsin Prepayment Penalty: Wisconsin Prepayment Penalty: Maximum prepay  allowed per state is 60 days interest calculated on 80% of the original loan amount ($XXXX).  Loan contracts for maximum calculated prepay of $XXXX, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483283   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Maryland Interest and Usury Prepayment Penalty: Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] State Compliance - Maryland Late Charge Grace Period Testing: Maryland Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
[2] State Compliance - Maryland Late Charge Percent and Amount Testing: Maryland Late Charge: Note late charge of X.XX%/$XXXX exceeds state maximum of 5% or $2, whichever is greater.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496427   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158483287   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483309   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] State Compliance - Delaware Late Charge Percent Testing: Delaware Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158483319   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158483320   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Mississippi Late Charge Percent and Amount Testing > $100,000: Mississippi Late Charge: Note late charge of X.XX%/$XXXX exceeds state maximum of 4% or $5, whichever is greater.
[2] State Compliance - Mississippi Prepayment Penalty: Mississippi Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% [in Years 1-5]. Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%, X.XX%, X.XX%, which exceeds the max allowable. Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-03): Appeal - ABA signed and dated XX/XX/XXXX.  CG
REVIEWER - GENERAL COMMENT (2024-04-04): Exception remains. Application date XX/XX/XXXX. ABA located in file dated XX/XX/XXXX.
Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158486308   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Illinois Late Charge Percent Testing: Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158486318   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Document provided at the time of closing   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158496441   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] 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
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483348   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158483350   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158483352   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Missouri Late Charge Grace Period Testing: Missouri Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158483369   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Illinois Late Charge Percent Testing: Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
[2] 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.
[2] 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).
  BUYER - GENERAL COMMENT (2024-04-09): 4/9/2024: Appeal. The final TIL in Clarity doc # 0198/D#0642 was executed onXX/XX/XXXXotXX/XX/XXXXTherefore, the disbursement date ofXX/XX/XXXX was well within the 3 days after consummation. LL
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, Notary date is XX/XX/XXXX.
BUYER - GENERAL COMMENT (2024-04-17): Please see Security Instrument Page 3 D0002 showing owner XXXX as Trustee under Trust Number XXXX which was executed i day prior to close XX/XX/XXXX which by law is allowed. Please see Trustee's Deed of Trust page 40 D0005 as well as Declaration of Certification of Trust signed by borrower page 568 D0348. Title Policy verifies the same page 878-880 D0375.. RTC pages 180-181 D0199 verification borrower received 3 working days to cancel copy of calendar attached as well as TIL page 92 D0198.
REVIEWER - GENERAL COMMENT (2024-04-18): As noted in the comment Transaction DateXX/XX/XXXX but the transaction disbursedXX/XX/XXXX (prior to the 3 business day rescission period). Eligible to disburseXX/XX/XXXX. Exception remains.
BUYER - GENERAL COMMENT (2024-04-09): 4/9/2024: Appeal. The final TIL in Clarity doc # 0198/D#0642 was executed onXX/XX/XXXXotXX/XX/XXXXThe ROR doc #0199 also reflected full execution onXX/XX/XXXXTherefore, the disbursement date ofXX/XX/XXXX was well within the 3 days after consummation. LL
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, Notary date is XX/XX/XXXX.
BUYER - GENERAL COMMENT (2024-04-17): Please see Security Instrument Page 3 D0002 showing owner XXXX as Trustee under Trust Number XXXX which was executed i day prior to close XX/XX/XXXX which by law is allowed. Please see Trustee's Deed of Trust page 40 D0005 as well as Declaration of Certification of Trust signed by borrower page 568 D0348. Title Policy verifies the same page 878-880 D0375.. RTC pages 180-181 D0199 verification borrower received 3 working days to cancel copy of calendar attached as well as TIL page 92 D0198.
REVIEWER - GENERAL COMMENT (2024-04-18): As noted in the comment Transaction DateXX/XX/XXXX but the transaction disbursedXX/XX/XXXX (prior to the 3 business day rescission period). Eligible to disburseXX/XX/XXXX. Exception remains.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.

Federal Compliance - TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158483380   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] State Compliance - Alabama Late Charge Percent and Amount Testing: Alabama Late Charge: Note late charge of X.XX%/$29.00 exceeds state maximum of 5% or $10, whichever is greater.
[2] State Compliance - Alabama Prepayment Penalty: Alabama Prepayment Penalty: A prepayment penalty is not permitted under the Consumer Credit Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Disclosed payment on Note does not correspond with the loan amount, loan term, and interest rate on the loan.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496459   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Louisiana Late Charge Percent Testing: Louisiana Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] State Compliance - Louisiana Prepayment Penalty: Louisiana Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% (in Years 1-5).  Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%, X.XX%, X.XX%, which exceeds the max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Captured as per data source   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158483396   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   3             3 [3] State Compliance - (State High Cost Provision) New York High-Cost Loan (Ability to Repay not Verified): New York High-Cost Loan:  Borrower’s ability to repay not verified with reliable documentation.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided): New York High-Cost Loan: Borrower not provided with Aggregate Monthly Payment Disclosure statement.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided): New York High-Cost Loan: Borrower not provided with Consumer Caution and Home Ownership Counseling Notice.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided): New York High-Cost Loan: Counseling Disclosure not provided to borrower.
[3] State Compliance - (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold): New York High-Cost Loan: Lender financed points and fees in excess of 3% of the total loan amount.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage): New York High-Cost Loan: Mortgage does not contain legend advising loan is high-cost.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application): New York High-Cost Loan: Mandatory "Shop Around" Notice not included on loan application to applicant.
[3] State Compliance - (State High Cost) New York High-Cost Loan (Points and Fees): New York Anti-Predatory Lending Statute: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of X.XX% of the Total Loan Amount and $XXXX XXXX. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] 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.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   State Compliance - (State High Cost Provision) New York High-Cost Loan (Ability to Repay not Verified): "N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act."

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost) New York High-Cost Loan (Points and Fees): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    HC - High Cost C C C C C
XXXX   3158483418   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483419   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: Unable to determine if loan file contains CHARM Booklet due to missing information.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483427   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158483431   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
[2] Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483441   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158483456   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [2] Missing Document - XXXX Informed  Consumer Choice Disclosure is missing.: Disclosure: XXXX - Informed Consumer Choice Disclosure (Government Documents)   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] General Appraisal Requirements - Due to lack of appraised value, compliance tests requiring an LTV were run off an assumed value of a contract sales price or original loan amount, whichever applies.
[2] Miscellaneous Compliance - Prepayment Penalty Discrepancy: Final TIL / CD indicates loan has PPP, however file does not contain prepayment penalty addendum. Missing prepay data may result in invalid high cost, FNMA, and/or QM points and fees findings.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure is TIL disclosing MI dropping off after 38 months and calculated running through term of loan. BUYER - GENERAL COMMENT (2024-04-16): 04-16-2024  Appeal.  Subject loan is an XXXX loan and cannot have a prepayment penalty.  Please note the TIL states the loan "may" have a PPP, but does not specifically state that is does. The Note itself specifies there is no PPP in paragraph 5. MC
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, Exception is for variance of note not having a prepayment penalty and TIL stating may have a prepayment.
BUYER - GENERAL COMMENT (2024-04-16): 04/10/2024 - Appeal. Please see Final 1003 page 62/2816 D 0571 which reflects the Type of Property as SFR.  AS
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, Unable to determine specific property type at origination.
BUYER - GENERAL COMMENT (2024-04-19): Subject is an XXXX Streamline Refinance which could only be done on SFR Please see your Property report page 1 D00938 shows SFR Please see Homeowners policy page 762 D0570 as well as XXXX Connection page 154 D0029., I am also attaching rate lock which shows SFR
REVIEWER - GENERAL COMMENT (2024-04-19): Unable to determine specific property type (i.e. attached/detached) from images provided. Exception remains.
Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496487   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   1 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
BUYER - GENERAL COMMENT (2024-04-09): Please see flood cert page D0458 showing subject in flood zone C.
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, flood determination referencing is post origination.
      1             - A A A A A
XXXX   3158483507   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
  BUYER - GENERAL COMMENT (2024-04-17): Appeal. Please see uploaded doc.  Found ValueSure Property Valuation Report dated prior to closing showing property type as SFR.
BUYER - GENERAL COMMENT (2024-04-17): Please see uploaded doc showing property type.
REVIEWER - GENERAL COMMENT (2024-04-17): Unable to determine if attached or detached. Exception remains.
BUYER - GENERAL COMMENT (2024-04-19): We have already furnished ValueSure Property Valuation Report giving value of $XXXX and SFR. Please see Approval page 33 D0-528 which shows SFR and value used $XXXX. Also please look at Homeowners Policy page 557 D0013 which also shows 1 dwelling. Thank You
REVIEWER - GENERAL COMMENT (2024-04-19): Unable to determine specific property type at time of Origination  (i.e. to include attached/detached for Single Family Dwellings) with documentation provided. Exception remains.
      - B B B B B
XXXX   3158483519   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] Federal Compliance - Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material: Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-11): 4-11-24 APPEAL, Providing a copy of the signed HUD statement.  See also page 96, DOC ID 0065 IN Acuity.  /dp
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, HUD provided is estimated.
REVIEWER - GENERAL COMMENT (2024-04-19): EXCEPTION HISTORY - Exception Detail was updated on 04/19/2024 PRIOR Exception Detail: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
    Yes TR HUD Deficiency D D D D D
XXXX   3158496496   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - New York Prepayment Penalty: New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Itemization did not disclose $310 of the Title pick up Fee as prepaid finance charges.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483562   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158483563   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
  BUYER - GENERAL COMMENT (2024-04-09): 04/09/2024 Appeal: Please the DOC IDs D0132 and D0133 which states the Application Date is actually on XX/XX/XXXX. D0271 validates the borrower was sent the ARM Disclosure, the CHARM Booklet, and the ABA (DOC D0275) on XX/XX/XXXX which is within three days of the application. CK
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, initial lenders 1003 in loan file states XX/XX/XXXX.
BUYER - GENERAL COMMENT (2024-04-09): 04/09/2024 Appeal: Please the DOC IDs D0132 and D0133 which state the Application Date is actually on XX/XX/XXXX. D0271 validates the borrower was sent the ARM Disclosure, the CHARM Booklet, and the ABA (DOC D0275) on XX/XX/XXXX which is within three days of the application. CK
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, initial lenders 1003 in loan file states XX/XX/XXXX.
BUYER - GENERAL COMMENT (2024-04-09): 04/09/2024 Appeal: Please the DOC IDs D0132 and D0133 which state the Application Date is actually on XX/XX/XXXX. D0271 validates the borrower was sent the ARM Disclosure, the CHARM Booklet, and the ABA (DOC D0275) on XX/XX/XXXX which is within three days of the application. CK
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, initial lenders 1003 in loan file states XX/XX/XXXX.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158496508   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483566   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158483572   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Federal Compliance - ARM Disclosure Timing Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.
[2] State Compliance - California Prepayment Penalty: California Prepayment Penalty: Maximum prepay  allowed is 6 months interest calculated on 80% of the original balance ($XXXX).  Loan contracts for maximum calculated prepay of $XXXX, which exceeds max allowable. Prepay may be impermissible depending on the lender's license type.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158483587   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158483588   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   3 [2] Insurance Documentation - Flood Insurance Error: Policy number is not provided.           3 [3] 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.     Federal Compliance - Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158496511   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158483603   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [2] Application / Processing - Missing Document: Flood Certificate not provided
[1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483607     $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158483612   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158483623   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158483632   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158496518   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL Itemization Did not disclose the settlement charge of $570 as a prepaid finance charge..
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496519   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXXused as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496521   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
          - B B B B B
XXXX   3158496522   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] State Compliance - Connecticut Prepayment Penalty Test: Connecticut Prepayment Penalty: A prepayment penalty is not permissible under the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-10): Cited prohibition is applicable to a mortgage broker. Prepayment penalty is payable to XXXX Mortgage which is the lender per Sec. 36a-485. (Formerly Sec. 36-440). Definitions. (19).
REVIEWER - GENERAL COMMENT (2024-04-16): The exemption from the prepayment penalty restriction established in the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act is not a blanket exemption for all mortgage brokers. The mortgage broker or mortgage lender must meet one of the exemptions from licensure established in Section 36a-487 of the Act.  While XXXX meets exemption under 36a-487(a)(1), it is not clear if the lender in the request meet any of the exemptions listed in this section. Please provide information about how each of the lenders meets ones of the exemptions listed in Section 36a-487.Exception remains.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496524   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Insurance Analysis - The Flood Insurance Policy effective date is after the Note Date.: Flood Insurance Policy Effective Date XX/XX/XXXX, Note Date XX/XX/XXXX   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
BUYER - GENERAL COMMENT (2024-04-11): Please see application for flood.
REVIEWER - GENERAL COMMENT (2024-04-12): Exception remains flood policy effective date is XX/XX/XXXX
      2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing. BUYER - GENERAL COMMENT (2024-04-12): Please see Sales Contract #246 buyer was aware of needing flood insurance at time of contract
REVIEWER - GENERAL COMMENT (2024-04-12): Exception remains, missing notice of special flood hazard from loan file.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158483666   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.           - B B B B B
XXXX   3158483674   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Exception remains, Missing notice of notice of special flood hazard from XX/XX/XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.
BUYER - GENERAL COMMENT (2024-04-16): 4/15/2024 Please see disclosure pkg uploaded for exception #30268599. JF
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, missing application date.
BUYER - GENERAL COMMENT (2024-04-16): 4/15/2024 Please see disclosure pkg uploaded with #30268599. JF
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, missing application date.
BUYER - GENERAL COMMENT (2024-04-15): 4/15/2024 Please see the  flood cert dated XX/XX/XXXX and signed by the borrower. The borrower was refinancing a condo and flood insurance was included with the master policy.
BUYER - GENERAL COMMENT (2024-04-15): 4/15/2024 Please see flood cert dated XX/XX/XXXX which is signed by the customer.
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, notice of special flood hazards dated XX/XX/XXXX not in loan file.
BUYER - GENERAL COMMENT (2024-04-17): 4/17/2024 Please re-review earliest food cert which is dated XX/XX/XXXX and signed by the customer which would constitute notice of a flood hazard.JF
REVIEWER - GENERAL COMMENT (2024-04-19): Exception remains, Missing Notice of special flood hazard from XX/XX/XXXX.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496534   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158483676   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
BUYER - GENERAL COMMENT (2024-04-09): 4/9/2024: Please reference page 726 doc ID 0292 for the Lender Flood Cert. LM
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, Flood determination referenced does not list any information.
      2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158483680   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496537   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower at the time of application.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower at the time of application.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List): Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
  BUYER - GENERAL COMMENT (2024-04-09): Please see page D0650 for confirmation of property type: Single Family
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, unable to determine property type at origination.
BUYER - GENERAL COMMENT (2024-04-10): Please see attached for verification subject was a SFR.  Thanks.
BUYER - GENERAL COMMENT (2024-04-10): Shows subject is a SFR.
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, unable to determine property type at origination SFR Attached or Detached.
BUYER - GENERAL COMMENT (2024-04-12): Please look at Home Value Explorer page 2370 D1812 which clearly states subject was SFR and I am enclosing a legible copy of hazard insurance which also verifies SFR
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, unable to determine property type at origination SFR Attached or Detached.
State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely): Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely: Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.
    - B B B B B
XXXX   3158483691   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower at the time of application.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower at the time of application.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List Timing): Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower at the time of application.
    State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely): Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely: Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.
    - B B B B B
XXXX   3158483698   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158496541   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483702   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   3             3 [3] Federal Compliance - Missing Final HUD-1:  No Document Used For Fee Testing Material: Missing Final HUD-1.  No document containing fees provided.  Any applicable Federal, State or Local compliance testing is unreliable.
[2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application No Fees: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation.  A lookback was performed to determine this application date. Due to missing HUD-1 or Closing Disclosure, no fees were used in testing.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
  BUYER - GENERAL COMMENT (2024-04-04): 04/04/2024 - Appeal: Please see DOC D0722 – Loan approval which states the property type is a SFR, D0557 – Market Intelligence Report - confirms SFR, and  D0762 which validates the subject property is a SFR Attached. CK
REVIEWER - GENERAL COMMENT (2024-04-04): Exception remains.  D0722 and D0557 does not include if Single Family Detached or Single Family Attached.  D0762 is not from time of Origination.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
  Yes TR Indeterminable D D D D D
XXXX   3158483733   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158483765   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
  BUYER - GENERAL COMMENT (2024-04-09): 04/09/2024 Appeal: Please see DOC D0209, disclosure notices, which contains the flood insurance notification. The flood notification states the borrower will be asked to acknowledge their receipt of this information. D0242 is the borrower’s acknowledgment. CK
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, missing Notice of special flood hazard from loan file.
Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496561   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIl Itemization did no disclosure settlement closing escrow fee of $176 as prepaid finance charge.   Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158483776   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158483777   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496562   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158483784   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483806   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483808   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] 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.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - New York Prepayment Penalty: New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
  BUYER - GENERAL COMMENT (2024-04-11): Appeal:  Please provide statute
REVIEWER - GENERAL COMMENT (2024-04-12): Response to request. Citations listed.  N.Y. Comp. Code. R. & Regs. tit. 3, §§ 82.1(a), 82.7,N.Y. Gen. Oblig. Law § 5-501(3)(b).
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158483811   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - South Carolina CHL Complaint Agency Disclosure Timing Test: South Carolina Home Loan: Borrower not provided with a document, at time of application, specifying the agency designated to receive complaints or inquiries about the origination and making of the loan.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL itemization did not disclose an Attorney fee of $350, Flood cert fee of $12 and Assignment recording fee of $6 as prepaid finance charge.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

State Compliance - South Carolina CHL Complaint Agency Disclosure Timing Test: Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to the potential remedies available to a court, this exception carries elevated risk to an assignee during the initial 6 years after occurrence of the violation. After the expiration of this 6 year period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same level as during the initial 6 years for affirmative claims.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483826   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158483859   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [2] Application / Processing - Missing Document: Missing Final 1003
[1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - New York Prepayment Penalty: New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIl itemization did not disclose Assignment mortgage$70, Title closer pick-up fee$175.00 and Title courier/Messenger fee $60 as prepaid finance charge.
BUYER - GENERAL COMMENT (2024-04-09): Please see page D0007 showing actual disbursement date of XX/XX/XXXX.
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, Disbursement date from HUD is XX/XX/XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158483868   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty): Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 60 days interest on the unpaid principal balance.
[2] State Compliance - Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 2% of the unpaid principal balance of the loan.: Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

State Compliance - Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty): Assignee liability is unclear.  Purchasers and assignees of Minnesota mortgage loans would not appear to be liable for violations of the Act. However, effective 8/1/07, although there does not appear to be any explicit assignee liability, because a new private right of action permits a court to award statutory damages equal to the amount of all lender fees included in the amount of the principal of the residential mortgage loan, there is the potential that secondary market participants may be adversely affected.

State Compliance - Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 2% of the unpaid principal balance of the loan.: Assignee liability is unclear.  Purchasers and assignees of Minnesota mortgage loans would not appear to be liable for violations of the Act. However, effective 8/1/07, although there does not appear to be any explicit assignee liability, because a new private right of action permits a court to award statutory damages equal to the amount of all lender fees included in the amount of the principal of the residential mortgage loan, there is the potential that secondary market participants may be adversely affected.

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496589   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158483878   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483883   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496597   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158496600   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
  BUYER - GENERAL COMMENT (2024-04-11): 4/11/2024 Appeal. Please reference page number 108, doc code 0477, for the final TIL with signature date of XX/XX/XXXX. RC
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, TIL referenced is not final.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483894   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158483912   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Massachusetts Prepayment Penalty: Massachusetts Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 3 months interest  ($XXXX).
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496608   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496614   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely): Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower at the time of application.
[2] State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely: Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower at the time of application.
[2] State Compliance - Michigan Consumer Mortgage Protection Act (Counseling Agencies List): Unable to test counseling agencies list due to missing information.
[2] State Compliance - Michigan Prepayment Penalty: Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing: Unable to test Affiliated Business Disclosure due to missing information.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL Itemization did not disclose Settlement/Closing/Escrow Fee of $175 and Title Courier/Messenger Fee of $20.00 as prepaid finance charges.
  State Compliance - Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely): Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

State Compliance - Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely: Assignee liability is unclear.  Purchasers and assignees would not appear to be liable for violations of the Act, except to the extent involved I violations arising from servicing or collecting.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496615   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - District of Columbia Prepayment Penalty: District of Columbia Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX). Prepay language states prepay will not exceed maximum permitted by applicable law.
          - B B B B B
XXXX   3158483941   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Insurance Documentation - Missing Document: Flood Insurance Policy not provided
[1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483944   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158483945   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496616   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - New York Prepayment Penalty: New York Prepayment Penalty: A prepayment penalty is not permissible on an adjustable rate loan less than $XXXX and an introductory period less than 5 years.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] 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.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing a lower index than available within look back. Lowest index within look back is X.XX%.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158496620   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL itemization did disclose an Prepaid interest of $221.76  as prepaid finance charge.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158483982   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158483986   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Rate/Term   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - Disparity in Occupancy - Not High Cost and Not Higher Priced: The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Investment).           - B B B B B
XXXX   3158496621   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.
Finance Charge Variance of XXXX is due to difference in lender's accepted payment stream as per final til and actual calculated payment stream.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158483994   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003
[1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.
BUYER - GENERAL COMMENT (2024-04-15): 4-12-24 APPEAL, Providing evidence the ARM disclosure was provided to the borrower at the time of Lenders application.  /dp
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, missing ARM disclosure dated within 3 days of application from loan file.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496622   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing a lower index than available within look back. lowest index within look back is X.XX%. BUYER - GENERAL COMMENT (2024-04-15): 4-15-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  See Trailing documents uploaded to exception ID 30269516  /dp
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-15): 4-15-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  See Trailing documents uploaded to exception ID 30269516  /dp
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-15): 4-15-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  /dp
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-15): 4-15-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  See Trailing documents uploaded to exception ID 30269516  /dp
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484010   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   1 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           1             - A A A A A
XXXX   3158486368   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484032   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.
BUYER - GENERAL COMMENT (2024-04-09): 4/9/24- Please review for rounding. TC
REVIEWER - GENERAL COMMENT (2024-04-09): Rounding per the Note .001%. Exception remains.
Commitment letter indicates the Index is X.XX% The Index per the lookback is X.XX%
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496632   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Compliant Test: TIL variable rate disclosure: ARM loan program disclosure does not match terms of loan.
[2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Compliant Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496636   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
  BUYER - GENERAL COMMENT (2024-04-10): Appeal - Various documents in the loan file reflect the subject property type as SFR.  Loan application, appraisal and property report reflect as SFR.  CG
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains. Unable to determine property type at time of origination SFR Attached or SFR Detached.
BUYER - GENERAL COMMENT (2024-04-23): Please see page 510-511 D0078 Home Value Explorer that states address is a residential single family residence- I am also attaching the dwelling insurance as I can see you do not the full policy- Also enclosing mortgage history for area which you don't have all of which indicate the subject is 1 building residential
BUYER - GENERAL COMMENT (2024-04-23): sorry Mortgage history for area
REVIEWER - GENERAL COMMENT (2024-04-23): Exception remains, unable to determine specfic property type at origination. Documents reference a SFR. Unable to determine if the SFR is attached, Detached or a PUD.
      - B B B B B
XXXX   3158496642   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: IL itemization did not disclose processing fee of $550, Wire transfer fee of $35 and wire fee of $30 as prepaid finance charges. Additionally, Finance charge under disclosure due to Prepaid interest fee amount of $511.83 and over disclosure due to Settlement fee of $360 BUYER - GENERAL COMMENT (2024-04-16): 4-16-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  /dp
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, copy of affiliated business disclosure from XX/XX/XXXX is missing from loan file.
Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496644   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158484091   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484104   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003
[1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496649   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.     - B B B B B
XXXX   3158496654   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] State Compliance - Connecticut Prepayment Penalty Test: Connecticut Prepayment Penalty: A prepayment penalty is not permissible under the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] 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.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158496657   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Federal FACTA Disclosure Timing Test: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158496658   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158496659   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
          - B B B B B
XXXX   3158484136   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
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.   Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158484149   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
  BUYER - GENERAL COMMENT (2024-04-10): 04-10-2024  Appeal.  XXXX acknowledges the missing lender 1003; however, the loan file does contain a lender letter specifically stating the application was received on XX/XX/XXXX which should establish an valid application date. The ARM dosclosure is dated XX/XX/XXXX. MC
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-10): 04-10-2024  Appeal.  XXXX acknowledges the missing lender 1003; however, the loan file does contain a lender letter specifically stating the application was received on XX/XX/XXXX which should establish an valid application date. The ARM dosclosure is dated XX/XX/XXXX. MC
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-10): 04-10-2024  Appeal.  XXXX acknowledges the missing lender 1003; however, the loan file does contain a lender letter specifically stating the application was received on XX/XX/XXXX which should establish an valid application date. MC
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-12): 04-12-2024  Appeal2.  Please confirm receipt of Lender Letter which specifies the Application Date as XX/XX/XXXX.  This was included in prior appeal docs, but unable to access in Acuity now. Uploading as seperate document now.  MC
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used. Application received date not acceptable.
BUYER - GENERAL COMMENT (2024-04-10): 04-10-2024  Appeal.  XXXX acknowledges the missing lender 1003; however, the loan file does contain a lender letter specifically stating the application was received on XX/XX/XXXX which should establish an valid application date. The ABA dosclosure is dated XX/XX/XXXX. MC
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158484151   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   1             1             - A A A A A
XXXX   3158496678   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158484159   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Federal FACTA Disclosure Timing Test: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158484170   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158484173   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Insurance Documentation - Flood Insurance Error: Insurance premium was not provided.
[2] Insurance Documentation - Missing Document: Flood Insurance Policy not provided
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
      2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Federal Compliance - Flood Insurance Policy Missing: The subject property is in a flood zone, evidence of flood insurance was not provided/obtained. Failure to obtain and disclose required insurance may result in additional federal and/or state compliance violations.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
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.
  Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158496682   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.           - B B B B B
XXXX   3158496683   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   3             3 [3] Federal Compliance - Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material: Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
        Yes TR HUD Deficiency D D D D D
XXXX   3158484181   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - (Missing Data) Flood Hazard Zone: Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone indicator was not provided. The applicable flood zone related testing cannot be performed.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-15): 4.15.24 Appeal page897of4095 D-0663 Notice of Special Flood dated XX/XX/XXXX signed  XX/XX/XXXX-reasonable time before Note date XX/XX/XXXX refinance kindly rescind.gs
BUYER - GENERAL COMMENT (2024-04-15): attached hereto also
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains missing flood determination from origination.
      - B B B B B
XXXX   3158484189   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
[2] State Compliance - Wisconsin Prepayment Penalty ARM Test: Wisconsin Prepayment Penalty:  Adjustable rate loan containing prepayment penalty did not provide disclosure stating that there are also loans available without prepayment penalties.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158484190   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158484202   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-11): 4/11/2024 Appeal. Please reference page number 3756, doc code 0635, for Disclosure Letter dated XX/XX/XXXX showing the ARM Loan Disclosure was provided to the borrower within 3 business days of application. RC
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, missing Arm disclosure from XX/XX/XXXX
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158484207   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           3 [3] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date and RTC Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
  BUYER - GENERAL COMMENT (2024-04-12): 4/12/2024: Appeal - Please refer to Closing Instructions (D0022) and ROR (D0184). ROR was provided to the borrower at closing and document is initialed acknowledging receipt. SG
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, TIL not dated by borrower.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
  Yes TR Indeterminable D D D D D
XXXX   3158484211   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158496697   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484215   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. REVIEWER - GENERAL COMMENT (2024-04-09): Exempt from federal, state and local high cost testing.  Exception regraded to EV2-B.       - B B B B B
XXXX   3158484223   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty): Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 60 days interest on the unpaid principal balance.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-12): 4/12/2024 Please re-review the multi disclosure/application addendum provided mailed to the  borrower from XXXX dated XX/XX/XXXX which acknowledges receipt of the Consumer Handbook on ARM mortgages and the ARM Disclosure at pg 54 #D0714. The date of XX/XX/XXXX is 1 day after the accepted initial application utilized for this loan. JF
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
State Compliance - Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty): Assignee liability is unclear.  Purchasers and assignees of Minnesota mortgage loans would not appear to be liable for violations of the Act. However, effective 8/1/07, although there does not appear to be any explicit assignee liability, because a new private right of action permits a court to award statutory damages equal to the amount of all lender fees included in the amount of the principal of the residential mortgage loan, there is the potential that secondary market participants may be adversely affected.     - B B B B B
XXXX   3158496698   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - New Jersey Prepayment Penalty: New Jersey Prepayment Penalty: No prepayment penalties are permissible in the state of New Jersey. Prepay language states prepay will not exceed maximum permitted by applicable law.
          - B B B B B
XXXX   3158496701   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158496702   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - New York Prepayment Penalty: New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to verify finance charge under disclosure due to missing TIL Itemization.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158484249   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TIL APR Tolerance Irregular Transaction: Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Disclosed payment on Note does not correspond with the loan amount, loan term, and interest rate on the loan.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TIL APR Tolerance Irregular Transaction: TILA APR -  subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484260   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496706   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-17): Appeal. Please see attached and D0294. Final TIL Disclosure dated XX/XX/XXXX and signed by the borrower on XX/XX/XXXX was found in file at the time of review.
REVIEWER - GENERAL COMMENT (2024-04-19): Exception remains, Document referenced does not appear to belong to exception.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158484270   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484274   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TIL APR Tolerance Irregular Transaction: Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing an index of X.XX% and the lowest index within look back is X.XX%. BUYER - GENERAL COMMENT (2024-04-09): 04/09/2034 Appeal: Please see DOC D0134 for the Initial 1003 which is dated XX/XX/XXXX. DOC D0014 confirms the application date of XX/XX/XXXX. CK
REVIEWER - GENERAL COMMENT (2024-04-09): Document provided is Broker initial application. Alt source of app date was approved by client for loans missing Lender Initial application date. Exception remains.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TIL APR Tolerance Irregular Transaction: TILA APR -  subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484281   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496713   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] State Compliance - Connecticut Prepayment Penalty Test: Connecticut Prepayment Penalty: A prepayment penalty is not permissible under the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-10): Cited prohibition is applicable to a mortgage broker. Prepayment penalty is payable to XXXX which is the lender per Sec. 36a-485. (Formerly Sec. 36-440). Definitions. (19)
REVIEWER - GENERAL COMMENT (2024-04-16): The exemption from the prepayment penalty restriction established in the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act is not a blanket exemption for all mortgage brokers. The mortgage broker or mortgage lender must meet one of the exemptions from licensure established in Section 36a-487 of the Act.  While XXXX meets exemption under 36a-487(a)(1), it is not clear if the lender in the request meet any of the exemptions listed in this section. Please provide information about how each of the lenders meets ones of the exemptions listed in Section 36a-487.
Exception remains.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158484302   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484310   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484315   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - New York Prepayment Penalty: New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing         - B B B B B
XXXX   3158484332   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484344   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484352   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496726   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   1 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           1             - A A A A A
XXXX   3158484360   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Rate/Term   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
  REVIEWER - GENERAL COMMENT (2024-04-09): Exempt from federal state and local high cost testing. Exception regraded to EV2-B.       - B B B B B
XXXX   3158484365   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496730   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
  REVIEWER - GENERAL COMMENT (2024-04-09): Exempt from federal state and local high cost testing.  Exception regraded to EV2-B.       - B B B B B
XXXX   3158496733   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing
Federal Compliance - Final TIL Finance Charge Under Disclosed: Commitment Letter  indicate the Index used was X.XX%. The minimum Index available in our look-back period is X.XX%.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158484381   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Til Itemization did not disclose of Prepaid Interest $305.22, Sign In Fee $200 as Prepaid Finance Charge.
BUYER - GENERAL COMMENT (2024-04-12): XX/XX/XXXX Please re-review pg 133 #D0169 which is the XXXX Price break down and reports the initial application  document date of Friday, XX/XX/XXXX reported on the  LAS. The ABA located at pg. 112 #D0154 is dated XX/XX/XXXX which is 3 business days later. The XXXX CBR located at pg. 171 #D0052 and XXXX GFE located at pg. 87 #D0143, all dated XX/XX/XXXX.
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, missing signed affiliated business disclosure from  0XX/XX/XXXX from loan file.
BUYER - GENERAL COMMENT (2024-04-16): 04-16-2024  Appeal.  AMC LASR shows a $200 Sign In fee which should not be included in PPFCs. $200 is the notary fee paid to a third party provider an shoulld be excluded from PPFCs. Removal of this fee will reduce FC into tolerance. MC
REVIEWER - GENERAL COMMENT (2024-04-18): While notary fees are excluded from finance charges and APR calculations, only the notary fee portion is excludable but signing fees and mobile services are not and these would be included as finance charges. Commentary to Regulation Z 1026.4(e)(1) provides:
1. Notary fees. In order for a notary fee to be excluded under §1026.4(e)(1), all of the following conditions must be met:
2. The document to be notarized is one used to perfect, release, or continue a security interest.
3. The document is required by law to be notarized.
iii. A notary is considered a public official under applicable law.
1. The amount of the fee is set or authorized by law.
If evidence can be provided verifying which portion of the "Sign-up/Notary Fee" was for notarizing documents as detailed above, that portion can be excluded from finance charges.
Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496738   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - New Jersey Prepayment Penalty: New Jersey Prepayment Penalty: No prepayment penalties are permissible in the state of New Jersey. Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed TIL utilizing a lower index than available within look back. Lowest index within look back is X.XX%.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496741   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484395   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.     - B B B B B
XXXX   3158484407   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158496743   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - TIL APR Tolerance Irregular Transaction: Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Commitment Letter indicate the Index used was X.XX%. The closest Index available in our look-back period is X.XX%
BUYER - GENERAL COMMENT (2024-04-10): 04/10/2024 Appeal: Please see DOC D0188 which confirms the ARM disclosure was provided to the borrower. CK
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains, missing ARM disclosure from loan file.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TIL APR Tolerance Irregular Transaction: TILA APR -  subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158484419   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Payoff Statement Missing: Missing Payoff Statement: Unable to determine if a prepayment penalty was included in the pay-off which may impact high cost findings.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484421   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   1 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           1             - A A A A A
XXXX   3158484422   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158484433   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158484435   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   1             1             - A A A A A
XXXX   3158484444   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484445   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] State Compliance - (State High Cost Provision) Arkansas High-Cost Loan (Certification of Counseling): Arkansas High-Cost Loan: No evidence of certification from a HUD-approved third party counselor that borrower has received counseling on the advisability of the loan transaction.
[3] State Compliance - (State High Cost) Arkansas High-Cost Loan (Points and Fees): Arkansas Home Loan Protection Act: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  X.XX% of the Total Loan Amount. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] Miscellaneous Compliance - Alternate source used for application date
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   State Compliance - (State High Cost Provision) Arkansas High-Cost Loan (Certification of Counseling): Assignee Liability:  Purchasers and assignees subject to all affirmative claims and any defenses that the borrower could assert against the original creditor or broker. If the assignee or purchaser did not “personally participate in the making or approving” of the high cost home loan, liability is limited to the amount of all remaining indebtedness and the total amount paid by the borrower in connection with the transaction.  If the assignee or purchaser did "personally participate in the making or approving", liability may be unlimited, and penalties may include: (i) rescission; (ii) the loan being voided for intentional violations of the Act; (iii) actual damages; (iv) statutory damages equal to 25% of the finance charges, plus 10% of the amount financed; (v) punitive damages for malicious or reckless violations; (vi) costs and attorneys’ fees; and (vii) injunctive, declaratory or other equitable relief. The right of rescission granted under HOEPA will be available to a borrower by way of recoupment against and party foreclosing on a high cost home loan.

State Compliance - (State High Cost) Arkansas High-Cost Loan (Points and Fees): Assignee liability but safe harbor if ‘reasonable due diligence’ is performed (which is not defined).  Assignees are also only liable if they participated in the making or approval of the loan.  Otherwise, liability is limited.  SOL 2 years from date of violation or at any time as a defense to foreclosure.  Intentional violation renders loan void.  Other violations may result in statutory damages equal to 25% of finance charges plus 10% of amount financed, actual damages, punitive damages for “reckless violations,” and equitable, declaratory or injunctive relief in enforcing compliance, plus costs and reasonable attorney’s fees. Rescission is available throughout term of loan as a defense to an action to collect the debt.
    HC - High Cost C C C C C
XXXX   3158484447   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - (TX50(a)(6)) Texas Cash-out Loan  (TX Home Equity Disclosure/Notice Concerning Extensions of Credit Not Provided): Texas Constitution Section 50(a)(6): Missing date the Notice Concerning Extensions of Credit disclosure was provided, however file includes a signed acknowledgment stating that the owner(s) received the Notice at least 12 days prior to closing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure is due to TIL itemization did not disclose Settlement/Closing/Escrow Fee $150, Settlement/Closing/Escrow Fee $275, Tax Cert Fee $70.20 and is over disclosed with HUD Fee $420.20 as prepaid finance charge.
BUYER - GENERAL COMMENT (2024-04-09): 04/09/2024 Concur with missing doc however the Owners Notice should suffice. DA
REVIEWER - GENERAL COMMENT (2024-04-11): Please clarify the doc ID referring the owners notice.
State Compliance - (TX50(a)(6)) Texas Cash-out Loan  (TX Home Equity Disclosure/Notice Concerning Extensions of Credit Not Provided): Assignee Liability:  The lender or any holder of the note shall forfeit all principal and interest of the extension of credit if the lender or holder (1) fails to comply with the lender's or holder's obligations under the extension of credit and (2) fails to correct the failure to comply not later than the 60th day after the date the lender or holder is notified by the borrower of the failure to comply.  The lender or any holder of the note for the extension of credit shall forfeit all principal and interest if the extension is made by a person other than a person described or if the lien was not created under a written agreement with the consent of each owner and each owner's spouse, unless each owner and each owner's spouse who did not initially consent subsequently consents.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484448   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484464   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Wisconsin Prepayment Penalty: Wisconsin Prepayment Penalty: Maximum prepay  allowed per state is 60 days interest calculated on 80% of the original loan amount ($XXXX).  Loan contracts for maximum calculated prepay of $XXXX, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484469   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - TIL APR Tolerance Irregular Transaction: Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing amortization schedule.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - TIL APR Tolerance Irregular Transaction: TILA APR -  subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484486   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   3 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       3 [3] State Compliance - (TX50(a)(6)) Texas Cash-out Loan  (Loan closed prior to expiration of 12-day cooling off period): Texas Constitution Section 50(a)(6): Loan closed prior to the 12th day after the later of the application date or the date the Notice Concerning Extensions of Credit was provided.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - (TX50(a)(6)) Texas Cash-out Loan (T-42 Endorsement Not Obtained): Texas Constitution Section 50(a)(6): Acceptable FNMA title insurance endorsements not obtained for home equity loan.  Although the loan file contains the T-42 Endorsement, there is no evidence the Title Policy includes the Texas T-42.1 endorsement. (The loan is a Texas Section 50 (a)(6) home equity loan.)
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-09): 04/09/2024- Reference is made to D0207 Owner's Affidavit that specifically covers that the minimum 12 days issue.  Reference specifically Page 1 Notice, Application and Counting 12 Days Sections.  DA
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, application date XX/XX/XXXX and loan closed XX/XX/XXXX.
State Compliance - (TX50(a)(6)) Texas Cash-out Loan  (Loan closed prior to expiration of 12-day cooling off period): Assignee Liability:  The lender or any holder of the note shall forfeit all principal and interest of the extension of credit if the lender or holder (1) fails to comply with the lender's or holder's obligations under the extension of credit and (2) fails to correct the failure to comply not later than the 60th day after the date the lender or holder is notified by the borrower of the failure to comply.  The lender or any holder of the note for the extension of credit shall forfeit all principal and interest if the extension is made by a person other than a person described or if the lien was not created under a written agreement with the consent of each owner and each owner's spouse, unless each owner and each owner's spouse who did not initially consent subsequently consents.

State Compliance - (TX50(a)(6)) Texas Cash-out Loan (T-42 Endorsement Not Obtained): This is a Secondary Market requirement by the GSEs and some investors.  (This Endorsement provides coverage against certain Texas 50(a)(6) exceptions at closing.)
    State - NC C C C C C
XXXX   3158496760   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158484503   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-12): 4/12/2024 Please review the initial welcome/disclosure letter mailed to the borrower uploaded below. JF
BUYER - GENERAL COMMENT (2024-04-12): 4/12/2024 Added Lender initial welcome and disclosure letter and file submission which reports lender file submitted same day as welcome letter. JF
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, missing application date.
BUYER - GENERAL COMMENT (2024-04-12): 4/12/2024 Please re-review pg. 98 #D1371 which is the Broker provided initial GFE dated XX/XX/XXXX. While the document is not lender provided the Borrower did sign for having received the Consumer Handbook on ARM Mortgages. JF
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, missing application date.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496762   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158484526   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Federal FACTA Disclosure Timing Test: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
  BUYER - GENERAL COMMENT (2024-04-15): Please the attached origination AVM which indicates the subject property is a single family residence.
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, missing specific property type from origination.
BUYER - GENERAL COMMENT (2024-04-17): The ValueSure Property Report previously provided is from origination; dated XX/XX/XXXX with a value of $XXXX used in the loan approval.
REVIEWER - GENERAL COMMENT (2024-04-17): Unable to determine if attached or detached from the documentation provided. Exception remains.
BUYER - GENERAL COMMENT (2024-04-18): 04-18-2024  Appeal.  Please find attached ValuSure AVM and Market Intelligence property condition report used to support property type as SFR. Please see 4 page trailing docs added 1:37pm 04-18. MC
REVIEWER - GENERAL COMMENT (2024-04-19): Unable to determine specific property type at time of Origination  (i.e. to include attached/detached for Single Family Dwellings) with documentation provided. Exception remains.
BUYER - GENERAL COMMENT (2024-04-15): Please see RTC page 284 D0614 showing midnight of the 15th and Please see TIL page 65 D0615 dated XX/XX/XXXX. Saturday could not be included XXXX due to a Federal Holiday Veterans Day. I have attached the information for your review
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, Exception generating due to Disbursement date on HUD XX/XX/XXXX.
Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.     - B B B B B
XXXX   3158484541   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
  BUYER - GENERAL COMMENT (2024-04-10): Appeal: PPP addendum is written such that the prepayment charge is only applicable if the current interest rate the borrower is required to pay is 8% or less
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, The prepay language states that "if the then current interest rate I am required to pay is 8% or less", then the prepayment penalty is applicable. The prepayment penalty period is 12 months. The initial interest rate on this loan (that would be applicable in those first 12 months) is X.XX%, which therefore means the prepayment penalty is applicable to this loan.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158484549   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] Federal Compliance - Federal and State High Cost Lookback Failures: Due to missing evidence of initial application date.  An application date of XX/XX/XXXX was used for Compliance testing.  The loan would result in a High Cost failure due to points and fees test failure based on the following application dates XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX.
[3] State Compliance - (State High Cost Provision) New York High-Cost Loan (Ability to Repay not Verified): New York High-Cost Loan:  Borrower’s ability to repay not verified with reliable documentation.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided): New York High-Cost Loan: Borrower not provided with Aggregate Monthly Payment Disclosure statement.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided): New York High-Cost Loan: Borrower not provided with Consumer Caution and Home Ownership Counseling Notice.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided): New York High-Cost Loan: Counseling Disclosure not provided to borrower.
[3] State Compliance - (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold): New York High-Cost Loan: Lender financed points and fees in excess of 3% of the total loan amount.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage): New York High-Cost Loan: Mortgage does not contain legend advising loan is high-cost.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application): New York High-Cost Loan: Mandatory "Shop Around" Notice not included on loan application to applicant.
[3] State Compliance - (State High Cost) New York High-Cost Loan (Points and Fees): New York Anti-Predatory Lending Statute: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  5.00000% of the Total Loan Amount. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed. BUYER - GENERAL COMMENT (2024-04-10): 4/10/2024 Please re-review the following listed documents: Per the initial welcome letter from the Lender at pg. 85 #D0063 the initial Lender application was submitted on XX/XX/XXXX and all disclosures were mailed. The CBR at pg. 201 #D0025, as well as the Pre-APP Disclosure at  pg. 86 #D0145, the FACTA at pg. 246  #D0061 as well as the Initial GFE at pg 94 #D0136 and initial TIL at  pg 96 # D0133 are also dated XX/XX/XXXX
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-10): 4/10/2024 Please re-review the following listed documents: Per the initial welcome letter from the Lender at pg. 85 #D0063 the initial Lender application was submitted on XX/XX/XXXX and all disclosures were mailed. The CBR at pg. 201 #D0025, as well as the Pre-APP Disclosure at  pg. 86 #D0145, the FACTA at pg. 246  #D0061 as well as the Initial GFE at pg 94 #D0136 and initial TIL at  pg 96 # D0133 are also dated XX/XX/XXXX
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-10): 4/10/2024 Please re-review the following listed documents: Per the initial welcome letter from the Lender at pg. 85 #D0063, , the application had been submitted XX/XX/XXXX. Pg. 86 #D0145 is the Pre-Application Disclosure dated XX/XX/XXXX. Pg. 201 #D0025 is the CBR dated XX/XX/XXXX. The Facta at pg. 246 #D0061, the GFE at pg. 94 #D0136 and Initial TIL at pg. 96 #0133, all are dated XX/XX/XXXX. Initial Broker Application, Federal Truth in Lending, Pre-Application Disclosure and Broker GFE are all dated XX/XX/XXXX. JF
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
State Compliance - (State High Cost Provision) New York High-Cost Loan (Ability to Repay not Verified): "N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act."

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost) New York High-Cost Loan (Points and Fees): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    HC - High Cost C C C C C
XXXX   3158496777   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
  BUYER - GENERAL COMMENT (2024-04-11): 4/11/2024: Appeal: Please reference the following: Page 32 Doc ID 0315 Loan Approval reflects property type as SFR using AVM value from page 393 Doc ID 0294. Page 436 Doc ID 0293 Property Inspection Report lists the Property Type as Single Family. Page 365 Doc ID 0277 Title Policy did not check  Condo or PUD Endorsements. Loan application Schedule of RE type of property is SFR. LM
REVIEWER - GENERAL COMMENT (2024-04-11): Unable to determine property type at time of origination. If SFR attached or detached. Exception remains.
BUYER - GENERAL COMMENT (2024-04-12): 2nd Appeal. Page 436 Doc ID 0293 Property Inspection Report was done XX/XX/XXXX which is  prior to origination and the subject photo from the inspection shows it's detached. LM
REVIEWER - GENERAL COMMENT (2024-04-16): Unable to determine specific property type at origination. Exception remains.
Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158484555   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158484557   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484558   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158484591   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   1             1             - A A A A A
XXXX   3158496784   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.
    - B B B B B
XXXX   3158484592   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496793   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Flood Certificate Error: Certificate Number was not provided.
[2] Application / Processing - Missing Document: Missing Final 1003
  BUYER - GENERAL COMMENT (2024-04-18): The document currently opens when clicking on the trailing document uploaded at 3:59 pm  04-10-2024 1st page.  Please note the loan closed in XXXX and the flood certificate may look different than a modern day flood cert.  The document clearly identifies property address and Zone D and no flood insurance is required.
REVIEWER - GENERAL COMMENT (2024-04-22): Exception remains, missing flood certificate number from form received.
REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
      2 [2] 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.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
  BUYER - GENERAL COMMENT (2024-04-10): 04-10-2024 Appeal.  Please find ARM disclosure attached. MC
REVIEWER - GENERAL COMMENT (2024-04-12): ARM disclosure reviewed with initial file and trailing provided. Disclosure available is dated XX/XX/XXXX.  Exception related to timing- not provided to the borrower within three (3) days of application. Exception remains.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496794   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL Itemization did not disclose Loan Flood Certification (Life of Loan) of $16.50, Loan Origination Fee of $250.00, Settlement/Closing/Escrow Fee of $240.00 as prepaid finance charges. BUYER - GENERAL COMMENT (2024-04-09): 04-09-2024  Appeal.  There were pnly two PPFCs paid by the borrower, the XXXX MIP and interest of XXXX. The other items were paid by the seller.  Please see attached for suport. MC
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, Signed HUD in loan file does not list all fees except 2 as seller paid.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496795   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - TIL APR Tolerance Irregular Transaction: Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to lender disclosed MI dropping off after 36 months and calculated dropping off after 160 months.   Federal Compliance - TIL APR Tolerance Irregular Transaction: TILA APR -  subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496799   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [2] Insurance Documentation - Missing Document: Flood Insurance Policy not provided   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.
BUYER - GENERAL COMMENT (2024-04-08): flood policy uploaded
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, Flood binder provided is post origination.
      2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
  BUYER - GENERAL COMMENT (2024-04-08): See uploaded disclosure. ta
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, missing Notice of flood hazards from origination.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496801   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Status: Unable to determine if loan file contains CHARM Booklet due to missing information.
[2] Federal Compliance - Federal FACTA Disclosure Timing Test: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158484640   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496802   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   3 [2] Application / Processing - Missing Document: Flood Certificate not provided
[1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       3 [3] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
  BUYER - GENERAL COMMENT (2024-04-09): Please see page D0024 for borrower certification of receipt of ARM loan disclosure statement.
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, missing Arm disclosure from loan file.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
  Yes TR Indeterminable D D D D D
XXXX   3158496805   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158496808   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158484653   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484654   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXXis underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Amount finance variance is due to missing Attorney fees of $750, Prepaid finance charge of $-41.1, Title courier fee of $25, Pick up fee of $325 as prepaid finance charge.

Conditional Loan Approval indicates the Index used by the lender was X.XX%. The Index available within the look-back period is X.XX%.
BUYER - GENERAL COMMENT (2024-04-05): Final HUD-1
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains.  RTC eligible Disbursement date XX/XX/XXXX.  Date entered on RTC XX/XX/XXXX and Disbursed XX/XX/XXXX.The disbursement date should come from page one of the HUD. When page one is missing this information, we look for evidence of funding from the settlement agent. If none found, our system will use the “Interest From” date to be able to run compliance..
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158484655   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: The Flood Zone was determined on XX/XX/XXXX as per Flood Certificate hence the Lender provided Notice to Borrower for property being in flood hazard zone on XX/XX/XXXX which is less than 10 business days from the Note date.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL itemization did not disclose Title Courier/Messenger fee $45 Wire transfer fee $35, Wire/funding/disbursement fee $35 and  HUD 1 fee amount did not disclose  Settlement fee $210 and Tax research fee $31 as prepaid finance charge.
BUYER - GENERAL COMMENT (2024-04-04): 04/04/2024 Appeal: Please see DOC D0475. Subject transaction is a Refinance with an application date of XX/XX/XXXX. The property is a Condo with the Master Policy (D0333) including the Flood coverage. Taking into consideration that the borrower was aware of the Flood Hazard and the coverage is provided under the master policy, XX/XX/XXXX (date on the disclosure) would be considered reasonable. CK
REVIEWER - GENERAL COMMENT (2024-04-08): Exceptions remains, The final rule provides that delivery of notice must take place within a “reasonable time” before the completion of the transaction. What constitutes “reasonable” notice may vary according to the individual circumstances of a transaction. The preamble to the final rule states that the agencies generally continue to regard ten days as a “reasonable” time interval. However, in all cases an institution should bear in mind that a borrower should receive notice timely enough to ensure that borrower had opportunity to obtain flood insurance.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484665   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158484672   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.
    Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.     - B B B B B
XXXX   3158484674   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Lien - Missing evidence of lien position on Other Financing.: Lien Position: 2
[1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver
  REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
  BUYER - GENERAL COMMENT (2024-04-23): Please see Initial 1003 pages 657-663 dated loan officer section XX/XX/XXXX taken by telephone lender XXXX it is also stamped XX/XX/XXXX. I have attached disclosures including Arm disclosure sent within the 3 days page 2-7 and please look at page 9 which list all the disclosures that were sent.
REVIEWER - GENERAL COMMENT (2024-04-23): Exception remains. Document referenced is not acknowledged by borrower's signature.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158496811   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158496812   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] State Compliance - (State High Cost Disclosure) Illinois High Risk Home Loan (Consumer Caution Notice Not Provided): Illinois High Risk Home Loan:  Borrower not provided with Consumer Caution Notice.
[3] State Compliance - (State High Cost Provision) Illinois High Risk Home Loan (Ability to Repay not Verified): Illinois High Risk Loan:  Borrower’s ability to repay not verified with reliable documentation.
[3] State Compliance - (State High Cost Disclosure) Illinois High Risk Home Loan (Mortgage Awareness Program ("MAP") Not Provided): Illinois High Risk Home Loan: Borrower not notified of right to participate in Mortgage Awareness Program ("MAP").
[3] State Compliance - (State High Cost Provision) Illinois High Risk Home Loan (Negative Amortization Feature): Illinois High Risk Home Loan:  Mortgage loan contains an impermissible negative amortization feature.
[3] State Compliance - (State High Cost) Illinois High Risk Home Loan (Points and Fees): Illinois High Risk Home Loan Act: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of 5.00000% of the Total Loan Amount and $XXXX XXXX. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] City / Local Compliance - (City High Cost Provision) Chicago Predatory Loan (Ability to Repay not Verified): City of Chicago Predatory Loan:  Borrower’s ability to repay not verified with reliable documentation.
[2] City / Local Compliance - (City High Cost Provision) Chicago Predatory Loan (Negative Amortization Feature): City of Chicago Predatory Loan: Mortgage loan contains an impermissible negative amortization feature.
[2] City / Local Compliance - (City High Cost) Chicago Threshold Loan (Points and Fees): City of Chicago Anti-Predatory Lending Ordinance: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  5.00000% of the City Total Loan Amount. Points and Fees total $XXXX on a City Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] County Compliance - (County High Cost Provision) Cook County Predatory Loan (Ability to Repay not Verified): Cook County Predatory Loan:  Borrower’s ability to repay not verified with reliable documentation.
[2] County Compliance - (County High Cost Provision) Cook County Predatory Loan (Negative Amortization Feature): Cook County Predatory Loan: Mortgage loan contains an impermissible negative amortization feature.
[2] County Compliance - (County High Cost) Cook County Threshold Loan (Points and Fees): Cook County Predatory Lending Ordinance: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  5.00000% of the County Total Loan Amount. Points and Fees total $XXXX on a County Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-05): Please see attached Disclosure letter dated XX/XX/XXXX and Application Addendum signed by the borrower's on XX/XX/XXXX.Attached HMDA W/S also confirms application date of XX/XX/XXXX.
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, missing disclosure dated XX/XX/XXXX.
State Compliance - (State High Cost Disclosure) Illinois High Risk Home Loan (Consumer Caution Notice Not Provided): "Assignee Liability:  Any person who purchases or otherwise is assigned or subsequently holds a high risk home loan will be subject to all affirmative claims and defenses with respect to the loan that the borrower could assert against the lender or broker of the loan which include: (a) the inability to enforce any loan provision which violates the Act; and (b) liability under the IL Consumer Fraud and Deceptive Business Practices Act (CFDBA).
Under the CFDBPA, violators may be subject to: (a) actual damages; (b) civil money penalties of $50,000 or more; (c) suspension or revocation of applicable licenses; (d) a private right of action; and (e) injunctive, declaratory and other equitable relief. "

State Compliance - (State High Cost Provision) Illinois High Risk Home Loan (Ability to Repay not Verified): """Assignee Liability:  Any person who purchases or otherwise is assigned or subsequently holds a high risk home loan will be subject to all affirmative claims and defenses with respect to the loan that the borrower could assert against the lender or broker of the loan which include: (a) the inability to enforce any loan provision which violates the Act; and (b) liability under the IL Consumer Fraud and Deceptive Business Practices Act (CFDBA).
Under the CFDBPA, violators may be subject to: (a) actual damages; (b) civil money penalties of $50,000 or more; (c) suspension or revocation of applicable licenses; (d) a private right of action; and (e) injunctive, declaratory and other equitable relief. """

State Compliance - (State High Cost Disclosure) Illinois High Risk Home Loan (Mortgage Awareness Program ("MAP") Not Provided): "Assignee Liability:  Any person who purchases or otherwise is assigned or subsequently holds a high risk home loan will be subject to all affirmative claims and defenses with respect to the loan that the borrower could assert against the lender or broker of the loan which include: (a) the inability to enforce any loan provision which violates the Act; and (b) liability under the IL Consumer Fraud and Deceptive Business Practices Act (CFDBA).
Under the CFDBPA, violators may be subject to: (a) actual damages; (b) civil money penalties of $50,000 or more; (c) suspension or revocation of applicable licenses; (d) a private right of action; and (e) injunctive, declaratory and other equitable relief. "

State Compliance - (State High Cost Provision) Illinois High Risk Home Loan (Negative Amortization Feature): "AssigneeLiability Yes. Any natural or artificial person who purchases or otherwise is assigned or subsequently holds a high risk home loan will be subject to all affirmative claims and defenses with respect to the loan that the borrower could assert against the lender or broker of the loan. These claims and defenses include: (a) the inability to enforce any loan provision which violates the Act; and (b) liability under the IL Consumer Fraud and Deceptive Business Practices Act. Under the CFDBPA, violators may be subject to: (a) actual damages; (b) civil money penalties of $50,000 or more; (c) suspension or revocation of applicable licenses; (d) a private right of action; and (e) injunctive, declaratory and other equitable relief. An assignee will not be liable if it demonstrates by a preponderance of the evidence that it: (a) has in place, at the time of the purchase, assignment, or transfer of the loans, policies that expressly prohibit its purchase, acceptance of assignment or holding of any high risk home loans; (b) requires by contract that a seller, assignor, or transferor of high risk home loans to the purchaser, assignee or transferee that either: (i) the seller, assignor, or transferor will not sell, assign, or transfer any high risk home loans to the assignee; or (ii) the seller, assignor, or transferor is a beneficiary of a representation and warranty from a previous seller, assignor, or transferor to that effect; and (c) exercises reasonable due diligence at the time of the purchase, assignment, or transfer of high risk home loans, or within a reasonable period of time after the purchase, assignment, or transfer of such home loans, which is intended by the purchaser, assignee, or transferee, to prevent the purchaser, assignee, or transferee from purchasing or taking assignment or otherwise holding any high risk home loans. This reasonable due diligence requirement may be met by sampling and need not require loan-by-loan review. 815 § 137/135(d)(1)

 Capped Yes. A borrower’s recovery against a purchaser, assignee, or transferee of a high risk home loan is limited to the amount required to reduce or extinguish the borrower’s liability under the high cost home loan plus the amount required to recover costs, including reasonable attorney fees. Further a borrower may only assert claims against an assignee in an individual capacity (i.e., no class actions). Subject to these limitations, a borrower may assert an action against an assignee as follows: (a) within 5 years of the closing date of the closing date of a high risk home loan, if the claim asserts a violation of the Act in connection with the loan as an original action; and (b) at any time during the term of a high risk home loan, after an action to collect on the home loan or to foreclose on the collateral securing the home loan has been initiated, or the debt arising from the home loan has been accelerated, or the home loan has become 60 days in default, any defense, claim, counterclaim or action to enjoin foreclosure or preserve or obtain possession of the home that secures the loan. 815 § 137/135(d)(2)"

State Compliance - (State High Cost) Illinois High Risk Home Loan (Points and Fees): Purchasers or assignees of a high risk home loan will be subject to all affirmative claims and defenses  At any point during the term of the loan, a violation can be used as a defense to collect or accelerate the debt, foreclose, or after the loan is in default 60 days.

Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

City / Local Compliance - (City High Cost Provision) Chicago Predatory Loan (Ability to Repay not Verified): Assignee liability is unclear.  The Chicago Ordinance does not expressly contain any assignee liability provisions and presumably, assignees loans face no exposure to civil liability.

City / Local Compliance - (City High Cost Provision) Chicago Predatory Loan (Negative Amortization Feature): Assignee liability is unclear.  The Chicago Ordinance does not expressly contain any assignee liability provisions and presumably, assignees loans face no exposure to civil liability.

City / Local Compliance - (City High Cost) Chicago Threshold Loan (Points and Fees): Assignee liability is unclear.  The Chicago Ordinance does not expressly contain any assignee liability provisions and presumably, assignees loans face no exposure to civil liability.

County Compliance - (County High Cost Provision) Cook County Predatory Loan (Ability to Repay not Verified): Although assignees of predatory loans do not face exposure to civil liability, lenders that make predatory loans may not be awards contracts with the County of Cook.

County Compliance - (County High Cost Provision) Cook County Predatory Loan (Negative Amortization Feature): Although assignees of predatory loans do not face exposure to civil liability, lenders that make predatory loans may not be awards contracts with the County of Cook.

County Compliance - (County High Cost) Cook County Threshold Loan (Points and Fees): Although assignees of predatory loans do not face exposure to civil liability, lenders that make predatory loans may not be awards contracts with the County of Cook.
    HC - High Cost C C C C C
XXXX   3158484678   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] State Compliance - New Hampshire Prepayment Penalty First Lien: New Hampshire Prepayment Penalty:  Prepayment penalty terms on a first lien loan not printed in bold on the Note or Note Addendum.
  BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024 Unable to locate ARM loan program disclosure after review of Acuity and EIV. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No Action
BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024 Unable to locate Charm Handbook on Adjustable Rate Mortgages, Charm Booklet after review of Acuity or EIV. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action
BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024 Unable to locate initial application after review of Acuity and EIV. JF
REVIEWER - GENERAL COMMENT (2024-04-08): No action
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158484679   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Approval indicate the Index used was X.XX%. The minimum Index available in our look-back period is X.XX%.
BUYER - GENERAL COMMENT (2024-04-05): 4/5-Appeal:  Please review rounding for FIR.  Note indicated .125% however LAS Finance Charges indicate rounding of .001%.
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, Note and ARM rider indicate 0.125%.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484681   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158484682   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484684   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158484692   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of
Amount Financed.
BUYER - GENERAL COMMENT (2024-04-04): Appeal - Providing proof the borrower received the ARM disclosure on XX/XX/XXXX.  CG
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, missing disclosure from loan file.
BUYER - GENERAL COMMENT (2024-04-12): Appeal - Broker application date XX/XX/XXXX with Lender application date XX/XX/XXXX per application addendum, HMDA and pricing sheet. ARM booklet provided XX/XX/XXXX, within 3 days of the application date. Trailing docs for appeal added to the CHARM exception.  – SO
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, missing ARM disclosure from loan file.
BUYER - GENERAL COMMENT (2024-04-17): Appeal - See XXXX file # 0699068003 ARM Disclosure as per Disclosure Letter. - SO
REVIEWER - GENERAL COMMENT (2024-04-19): Letter does not include copy of the ARM Disclosure. Exception remains.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496818   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.     - B B B B B
XXXX   3158484702   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484705   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158484707   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158496822   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Rate/Term   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158496825   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Refinance Cash-out - Other   2             2 [2] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
  BUYER - GENERAL COMMENT (2024-04-04): Appeal – Letter attached from settlement agent certifying the HUD. - SO
REVIEWER - GENERAL COMMENT (2024-04-04): A Final HUD-1 is defined as a HUD-1 or HUD-1A document that is either signed by the borrower, stamped by the title company, or signed by the settlement agent depending on whether the property is located in an escrow state or non-escrow state. In an escrow state the Final HUD-1 may not be signed by the borrower but must be stamped by the title company or signed by the settlement agent at closing. The HUD-1 in file (and the same one provided with the cover letter) has a signature space for the Settlement Agent; however does not contain a signature or stamp. Due to APR and points and fees calculations required for high cost and various other anti-predatory lending regulations in scope, it is critical that a reliable source document is used as the basis for actual charges and costs at consummation used in compliance testing. Accordingly, the signature/stamp requirements previously discussed are the methods applied to ensure the HUD used for testing is the most updated and one acknowledged by the borrower/settlement agent as appropriate. When a HUD exception is cited, the exception is cited for visibility to indicate that compliance testing may not be conclusive if the HUD in file used for testing is estimated or not signed or stamped certified and not reflective of the final points and fees charged at consummation.
"
REVIEWER - GENERAL COMMENT (2024-04-05): Loan not subject to federal or state anti-predatory lending testing.  Exception regraded to EV2-B.
BUYER - GENERAL COMMENT (2024-04-05): Appeal – The Disclosure notice confirms that the ABA was sent to the Borrower(s) within 3 days of the application date. - SO
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, Missing affiliated business disclosure disclosed at application date.
Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158484722   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-05): Please see attached Disclosure Letter dated XX/XX/XXXX, which indicates the ARM Disclosure was provided within 3 business day of the application, XX/XX/XXXX.
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, missing arm disclosure from initial application date.
BUYER - GENERAL COMMENT (2024-04-09): Disclosure Letter
REVIEWER - GENERAL COMMENT (2024-04-10): Exception remains, missing arm disclosure from initial application date.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158484734   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           3 [3] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
  Yes TR Indeterminable D D D D D
XXXX   3158484743   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [1] Closing / Title - Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses:: Homestead Exemption Waiver           2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - New Jersey Prepayment Penalty: New Jersey Prepayment Penalty:  No prepayment penalties are permissible in the state of New Jersey.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484758   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158484761   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158496838   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-08): 4/8/2024 Unable to locate ARM loan program disclosure. JF
REVIEWER - GENERAL COMMENT (2024-04-09): No action as per comment
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158496841   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-17): Appeal. According to D0082 letter, CHARM booklet was enclosed when the letter was sent to the customer.
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, missing application date to determine timing..
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158484784   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] 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.
[2] State Compliance - Rhode Island Home Loan (Invoices for Third Party Fees Not in File - Unable to Determined if Bona Fide): Rhode Island Home Loan: No documentation in loan file to confirm third party fees listed on the HUD-1.
  BUYER - GENERAL COMMENT (2024-04-05): Please see attached for verification of rate which was used on all closing documents. This file was not a DU or LP approval so form is different.
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, Document provided does not list lock dates.
BUYER - GENERAL COMMENT (2024-04-04): Appeal:  Please provide the exact regulatory reference for the confirmation requirement stated in the detail.
BUYER - GENERAL COMMENT (2024-04-04): Appeal: Cited requirement is specific to a High Cost Home Loan which this is not.
REVIEWER - GENERAL COMMENT (2024-04-10): RI HLPA specifically exempts any national bank, federal savings bank, any “financial institution”, or wholly-owned subsidiaries thereof. RI exception eligible for downgrade to EV2-B.
State Compliance - Rhode Island Home Loan (Invoices for Third Party Fees Not in File - Unable to Determined if Bona Fide): A court, as injunctive relieve to an aggrieved consumer, may issue an order or injunction barring any judicial or non-judicial foreclosure or other lender action under the mortgage or deed of trust securing any home mortgage loan which violates this chapter (RI Stat 34-25.2-8)     - B B B B B
XXXX   3158484794   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Idaho Residential Mortgage Practices Act (Rate Lock Agreement Not Provided): Unable to test ID Rate Lock-In/Float Disclosure due to missing information.
[2] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
  REVIEWER - GENERAL COMMENT (2024-04-09): Exception regraded to EV2-B. Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

State Compliance - Idaho Residential Mortgage Practices Act (Rate Lock Agreement Not Provided): The Residential Mortgage Practices Act does not appear to provide for assignee liability.
    - B B B B B
XXXX   3158484803   XXXX XXXX $XXX XX XX/XX/XXXX UTD Purchase   2 [2] Application / Processing - Missing Document: Flood Certificate not provided
[2] Application / Processing - Missing Document: Missing Final 1003
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
      2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] 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.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
[2] Miscellaneous Compliance - Unable to determine occupancy, compliance results were generated using a defaulted value of Primary.
  BUYER - GENERAL COMMENT (2024-04-17): Appeal. Please see D0280 according to XXXX Agent Desktop property is Primary.
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, unable to determine occupancy at origination.
BUYER - GENERAL COMMENT (2024-04-23): Appeal.  The appraisal shows property is occupied.  PA
REVIEWER - GENERAL COMMENT (2024-04-23): Exception remains, appraisal stating owner occupied is the seller.
Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496849   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484821   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496857   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.     Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496869   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
    Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484885   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
    Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496876   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
    Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158496878   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - SAFE Act - Individual LO NMLS license status not approved: Unable to test Individual Loan Originator license status due to missing information.
[2] Federal Compliance - SAFE Act - Individual LO not licensed at time of application: Unable to test Loan Originator license due to missing information.
[2] Federal Compliance - SAFE Act - Individual LO NMLS does not match NMLS: Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan Originator NMLSR information on loan documents does not match NMLSR.
    Federal Compliance - SAFE Act - Individual LO not licensed at time of application: Liability appears to be limited to originators/licensees.

Federal Compliance - SAFE Act - Individual LO NMLS does not match NMLS: Liability appears to be limited to originators/licensees.
    - B B B B B
XXXX   3158496881   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (2010): Loan Amount on Final GFE does not match Note.
[2] Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (2010): Initial payment on GFE does not match actual payment on loan.
[2] Federal Compliance - RESPA (2010) - 10% Tolerance With Cure: RESPA (2010): 10% tolerance violation with evidence of cure provided on Final HUD-1.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - SAFE Act - Individual LO NMLS license status not approved: Unable to test Individual Loan Originator license status due to missing information.
[2] Federal Compliance - SAFE Act - Individual LO not licensed at time of application: Unable to test Loan Originator license due to missing information.
[2] Federal Compliance - SAFE Act - Individual LO NMLS does not match NMLS: Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan Originator NMLSR information on loan documents does not match NMLSR.
[2] 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.
  BUYER - GENERAL COMMENT (2024-04-18): System generated doc
BUYER - GENERAL COMMENT (2024-04-18): 4/18/4 - Appeal: see on pg 296 D 0017 of the file in Clarity Hud doc showing Title Insurance fee and Government Recording fee increase of more than 10%.. Attached is a system generated document showing highlighted of the Title Insurance fee $1,538 - $1,275.78 was paid by the lender and $262.22 was Cured.. also the $168 Recording fee was paid by the lender. Please review and rescind...eg
REVIEWER - GENERAL COMMENT (2024-04-22): Exception remains, subject exception is stating a 10% tolerance is cited but tolerance was cured.
BUYER - GENERAL COMMENT (2024-04-11): 04/11/2024 Appeal: Please see the original ABA sent to the borrower on XX/XX/XXXX (DOC - D0424). The borrower executed the same document at closing (DOC - D0183) CK
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, ABA from XX/XX/XXXX not signed
Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA (2010) - 10% Tolerance With Cure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - SAFE Act - Individual LO not licensed at time of application: Liability appears to be limited to originators/licensees.

Federal Compliance - SAFE Act - Individual LO NMLS does not match NMLS: Liability appears to be limited to originators/licensees.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158496884   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - (Missing Data) Unable to determine if loan is a same lender refi (Circuit 2, 5, 7, 8, 9, 10 or DC): Original Lender was not able to be determined. Unable to determine if correct TILA rescission form was used. (H-8 Form was used and property is in the 2 nd, 5 th, 7 th, 8 th, 9 th, 10 th, or District of Columbia)
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to verify finance charge under disclosure due to missing TIL Itemization. BUYER - GENERAL COMMENT (2024-04-05): Appeal:  The NY Attorney fee was excluded from finance charges due to the attorney fee being a legal fee rather than a loan closing fee.  Based on the attached invoice, the lender excluded the $600 legal fee from finance charges.
BUYER - GENERAL COMMENT (2024-04-05): attorney invoice
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, SitusAMC will, by default, consider a lender’s attorney fee to be a finance charge when there is no separate closing fee charged. Had there been a separate closing fee charged, we would treat a second attorney fee as a 4c7 fee under the assumption it was paid for the purpose of preparing loan-related documents (thereby allowing for the exclusion). Pursuant to 1026.4(a)(2)-2, if the creditor requires the use of a closing agent, then fees charged by the closing agent are included in the finance charge
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496887   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
    Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484902   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
    Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484915   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine finance charge variance due to missing itemization of amount financed. BUYER - GENERAL COMMENT (2024-04-05): 04/05/2024 Appeal:  Please check rounding used for FIR on the finance charge calculation.  Per note rounding is .125% however LAS FC chart indicates .001% for FIR. CK
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains, Under disclosure is due to fees as the total payment variance is only $0.03.
Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496893   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.     Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496895   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - 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
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
  BUYER - GENERAL COMMENT (2024-04-17): ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure was provided to the borrower within three (3) days of application.
Document #: D0105
REVIEWER - GENERAL COMMENT (2024-04-19): D0105 dated XX/XX/XXXX - date of closing. Exception remains.
BUYER - GENERAL COMMENT (2024-04-22): 04/22/2024 Sent Original 1003 dated by LO XX/XX/XXXX with Charm Appeal . Review pages 173-174 D0117 shows Charm booklet mailed to borrower as well Arm Loan program disclosure
REVIEWER - GENERAL COMMENT (2024-04-23): Exception remains. Document referenced is not acknowledged by borrower's signature.
BUYER - GENERAL COMMENT (2024-04-17): Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, was provided to the borrower within three (3) days of application. App date D0169 - (XX/XX/XXXX)
Receipt of CHARM Document #: D0105
REVIEWER - GENERAL COMMENT (2024-04-19): D0105 dated XX/XX/XXXX - date of closing. Exception remains.
BUYER - GENERAL COMMENT (2024-04-22): Please see Initial 1003 taking by phone dated by LO XX/XX/XXXX. Review pages 173-174 D0117 shows Charm booklet mailed to borrower as well as other disclosures XX/XX/XXXX
REVIEWER - GENERAL COMMENT (2024-04-23): Exception remains. Document referenced is not acknowledged by borrower's signature.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496897   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Insurance Documentation - Missing Document: Mortgage Insurance Certificate (MIC) not provided   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.     Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496898   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
    Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484932   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] 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.
  BUYER - GENERAL COMMENT (2024-04-18): Appeal:  refinance with same lender, but borrower did not receive any new advances.  PA
BUYER - GENERAL COMMENT (2024-04-18): Disregard prior comment.
REVIEWER - GENERAL COMMENT (2024-04-22): No action
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Third Circuit): TILA ROR Form - The Third Circuit has prior rulings that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form. Creditors are required to use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158496907   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [2] Missing Document - XXXX Informed  Consumer Choice Disclosure is missing.: Disclosure: XXXX - Informed Consumer Choice Disclosure (Government Documents)   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.   Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496911   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496919   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed. There is a Seller credit on page one of HUD for $12,000 which is not itemized therefore excluded.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496920   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Maryland Interest and Usury Prepayment Penalty: Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496922   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] State Compliance - Maryland Interest and Usury Prepayment Penalty: Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496925   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158484981   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024 - Appeal - Please reference D0331 - TIL dated XX/XX/XXXX marked as Final.
BUYER - GENERAL COMMENT (2024-04-05): Correction to previous comment - Appeal - Please reference D0332 - signed TIL dated XX/XX/XXXX marked as Final
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains. TIL D0332 is checked as Final but is not signed and Finance Charge Box includes "e" for Estimate.
TIL D0333 is checked as Final and signed but sill includes "e" for Estimated in the Finance Charge box.
Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496929   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158486528   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496937   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.
BUYER - GENERAL COMMENT (2024-04-05): Appeal - Providing Flood Cert.  CG
REVIEWER - GENERAL COMMENT (2024-04-08): Flood cert provided is not from time of loan origination. Exception remains.
      2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - (Missing Data) Flood Hazard Zone: Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone indicator was not provided. The applicable flood zone related testing cannot be performed.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496938   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Federal Flood Disclosure Timing not provided.
  Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485008   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485025   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.   Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485028   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.
BUYER - GENERAL COMMENT (2024-04-10): 4/10/2024: Appeal. Please see document # D0122 in Clarity showing subject property is a single family residence. LL
REVIEWER - GENERAL COMMENT (2024-04-12): Document provided not at time of Origination. Exception remains.
BUYER - GENERAL COMMENT (2024-04-16): 4/16/2024: Appeal. Please see document in Clarity that evidences subject property was a single family residence and has not change since. The documents in Clarity to reference are: D0001, D0116, D0117, D0163. LL
REVIEWER - GENERAL COMMENT (2024-04-17): Unable to determine attached or detached from documentation provided. Exception remains.
Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485034   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158485042   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485059   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158496954   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Disclosure dated XX/XX/XXXX.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Notice of Special Flood Hazard Disclosure Not Provided Timely: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496955   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
  BUYER - GENERAL COMMENT (2024-04-17): Found Initial 1003 dated XX/XX/XXXX. Doc #: D0557
REVIEWER - GENERAL COMMENT (2024-04-19): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496958   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496962   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXXin the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of
Amount Financed.
BUYER - GENERAL COMMENT (2024-04-15): 04-15-2024  Appeal.  AMC LASR includes $18.50 PPFC for Subordination Recording Fee.  However, this fee was paid to the county Clerk of the Circuit Court. It is listed as "Record Subordination Agreement" and paid to the clerk which means it is not a PPFC or recording Service Fee.  Removal of this fee from PPFCs will drop within tolerance level. Please review and advise. MC
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, The recording of a subordination agreement would not fall within the finance charge exclusions, specifically those exclusions related to security interest charges set forth in 12 CFR 1026.4(e). Further, see para 1(ii) to section 4(e) in the Commentary to Regulation Z, “ii. Charges not excludable. If the obligation is between the creditor and a third party (an assignee, for example), charges or other fees for filing or recording security agreements, mortgages, continuation statements, termination statements, and similar documents relating to that obligation are not excludable from the finance charge under this section.” The charge in question is a recording fee related to an agreement between the creditor and a third party for the subordination of a junior lien. Therefore, the charge is not excludable from the finance charge.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496964   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496966   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496970   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158496972   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485109   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158496977   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158485116   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL Itemization did not disclose Settlement/Closing/Escrow Fee of $200.00 as prepaid finance charges. BUYER - GENERAL COMMENT (2024-04-09): Please see page D0166 for final TIL.  Please advise as to what markings are being referenced.  Thank you for your help.
REVIEWER - GENERAL COMMENT (2024-04-09): Exception remains, e next to the finance charges
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485124   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to identify the TIL Finance Charge Tolerance due to itemization is missing.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496984   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496987   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
BUYER - GENERAL COMMENT (2024-04-19): Appeal:  $40 Notice of Settlement is a required recording fee in NJ to file the NOS.  It is correctly placed in the 1200 section and is not a prepaid.  The $50 Cancel Mortgage charge is also a cost to record the mortgage cancellation after payoff.  It is correctly placed in the 1200 section and is not a prepaid.
REVIEWER - GENERAL COMMENT (2024-04-22): EXCEPTION HISTORY - Exception Detail was updated on 04/22/2024 PRIOR Exception Detail: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $482,475.01 in the amount of $92.56.
REVIEWER - GENERAL COMMENT (2024-04-22): Exception remians, The Notice of Settlement is a fee charged in the state of NJ (NJ Rev Stat 46:26A-11) to record/document a notice that a specified property is being mortgaged by specified parties (consumer and lender) in order to ensure clear title in preparation for the recording of the security instrument. As such, the fee could arguably fall under §1026.4(c)(7) i and ii which are charges excluded from the finance charge. I've applied an offset for this fee.
The $50 Cancel Mortgage Fee is not being included in our finance charge calculation. The other fees included are as follows: $875 Attorney's Fee, $370 Commitment Fee, $5 Flood Cert Fee, $1,065.24 Prepaid Interest, $84 Tax Service Fee, $50 Title Courier, and $25 Wire Fee.
With the offset for the Notice of Settlement Fee, the finance charge is now underdisclosed by $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158496991   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.   Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485139   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine finance charge variance due to missing itemization of amount financed.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485149   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
BUYER - GENERAL COMMENT (2024-04-11): 4/10/2024: Appeal. Unable to proceed with review of exception need more information. The "Other 1" in the amount of $50 in LAS, is reflected on 814 and the charge is for Association fee, not a lender fee and is not a prepaid finance charge. $18 reflected on LAS as Assignment recording fee on line 1205 is not a prepaid finance charge. Please re-review charges for finance charge. LL
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, Association fee on HUD is paid to Lender.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158497002   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.     Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485162   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance: TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.     - B B B B B
XXXX   3158497006   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
  BUYER - GENERAL COMMENT (2024-04-05): 4/5/2024 Unable to locate a Notice of Special Flood Hazard Disclosure in Acuity or EIV
REVIEWER - GENERAL COMMENT (2024-04-08): No action. Comment provided as unable to locate.notice.
Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158485177   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485187   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] 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.
          - B B B B B
XXXX   3158485194   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.   BUYER - GENERAL COMMENT (2024-04-05): Appeal - Signed TIL is dated XX/XX/XXXX on top of page.  CG
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains. SitusAMC looks for the borrower’s signature date on the TIL to confirm borrower’s receipt of the required disclosures before loan consummation. Further, on rescindable transactions, the TIL signature date is used as the basis for date of receipt of material disclosures for purposes of determining one of the 3 dates triggering when rescission period begins.
Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485203   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Right of Rescission Timing - Receipt Date Missing: Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.
[2] State Compliance - South Carolina Home Loan (Complaint Agency Disclosure Not Provided): South Carolina Home Loan: Borrower not provided with a document specifying the agency designated to receive complaints or inquiries about the origination and making of the loan.
[2] Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.
    Federal Compliance - Right of Rescission Timing - Receipt Date Missing: TILA ROR - 3yrs for rescindable transactions.

State Compliance - South Carolina Home Loan (Complaint Agency Disclosure Not Provided): Exceptions occurring more than 6 years ago may be outside the states statute of limitations. Due to the potential remedies available to a court, this exception carries elevated risk to an assignee during the initial 6 years after occurrence of the violation. After the expiration of this 6 year period, the exception retains risk for claims raised as a defense to foreclosure, but not at the same level as during the initial 6 years for affirmative claims.

Closing / Title - (Doc Error) TIL Error: Borrower signature not dated.: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158497032   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158485226   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158497049   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158497056   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158497059   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing   Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158497061   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158497066   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497071   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] Federal Compliance - Federal and State High Cost Lookback Failures: Due to missing evidence of initial application date.  An application date of XX/XX/XXXX was used for Compliance testing.  The loan would result in a High Cost failure due to points and fees test failure based on the following application dates XX/XX/XXXX, XX/XX/XXXX.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided): New York High-Cost Loan: Borrower not provided with Aggregate Monthly Payment Disclosure statement.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided): New York High-Cost Loan: Borrower not provided with Consumer Caution and Home Ownership Counseling Notice.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided): New York High-Cost Loan: Counseling Disclosure not provided to borrower.
[3] State Compliance - (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold): New York High-Cost Loan: Lender financed points and fees in excess of 3% of the total loan amount.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage): New York High-Cost Loan: Mortgage does not contain legend advising loan is high-cost.
[3] State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application): New York High-Cost Loan: Mandatory "Shop Around" Notice not included on loan application to applicant.
[3] State Compliance - (State High Cost) New York High-Cost Loan (Points and Fees): New York Anti-Predatory Lending Statute: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  5.00000% of the Total Loan Amount. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] 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.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed. BUYER - GENERAL COMMENT (2024-04-08): Please detail the corresponding HUD line numbers for the $75 Courier Fee and $210 Other 1 fee contained on the LAS.
REVIEWER - GENERAL COMMENT (2024-04-09): Patriot Search $210.00 and Title Courier Fee $75.00 HUD Line # 1113 Itemized on Closing Statement D0156.. Exception remains.
BUYER - GENERAL COMMENT (2024-04-09): Search fees are not prepaid finance charges and should not be included in the NY test.
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains, The Patriot Act applies to all financial institutions and non-bank loan companies and requires entities to identify and verify and record borrowers identities and requires private financial information be released to the government. It is not generally a component of a title insurance or title exam. Patriot search charges do not fall under a specific exemption for finance charges under 1026.4 and are therefore included as a finance charge.
BUYER - GENERAL COMMENT (2024-04-11): It falls under "similar purposes" in 1026.4(c)(7)(i) and was paid to the title company (XXXX). If AMC disagrees please detail under which section of NY Banking Law 6-L(f) "Points and Fees" a patriot act search would fall under.
REVIEWER - GENERAL COMMENT (2024-04-16): We respectfully disagree that a Patriot Act Search fee would fall under “similar purposes” as it relates to treating the fee along with other title fees under 1026.4(c)(7) . The Patriot Act applies to all financial institutions and non-bank loan companies and requires entities to identify, verify and record a borrower’s identity and requires private financial information be released to the government. It is not generally a component of a title insurance. Patriot search charges do not fall under a specific exemption for finance charges under 1026.4 and is therefore included as a finance charge. Exception remains
BUYER - GENERAL COMMENT (2024-04-16): Please detail under which section of NY Banking Law 6-L(f) "Points and Fees" a patriot act search would fall.
REVIEWER - GENERAL COMMENT (2024-04-19): SitusAMC included the $210 patriot search fee in both the finance charge calculation and the NY points and fees test. As noted previously, patriot search charges do not fall under a specific exemption for finance charges under 1026.4 and are therefore included as a finance charge. SitusAMC does not consider a Patriot Act Search fee to fall under “similar purposes” as it relates to treating the fee along with real estate related title fees under 1026.4(c)(7). The Patriot Act applies to all financial institutions and non-bank loan companies and requires entities to identify, verify and record a borrower’s identity and requires private financial information be released to the government. It is not generally a component of title insurance.
 
As it relates to New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans, finance charges are included in the high cost points and fees definition under (f)  All items listed in 15 U.S.C. § 1605(a)(1) through (4), except interest or the time-price differential.
BUYER - GENERAL COMMENT (2024-04-15): Please the attached initial application which was taken over the phone on 4/9/2008.
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.
BUYER - GENERAL COMMENT (2024-04-15): AMC included $210 in Other Fee and $75 Courier fee which are not reflected on the Final HUD-1. The Escrow Deposit for open water charge of $188 should not be included in The Other Fee amount. Please provided details for charge described as "Other".
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, Other charge is for a patriot search.
BUYER - GENERAL COMMENT (2024-04-17): The fee of $210 for Patriot Search, which is include in the total of $620 on the Final HUD-1 is not a Prepaid Finance Charge and therefore should not have been included in the calculation. Please escalate.
REVIEWER - GENERAL COMMENT (2024-04-19): SitusAMC included the $210 patriot search fee in both the finance charge calculation and the NY points and fees test. As noted previously, patriot search charges do not fall under a specific exemption for finance charges under 1026.4 and are therefore included as a finance charge. SitusAMC does not consider a Patriot Act Search fee to fall under “similar purposes” as it relates to treating the fee along with real estate related title fees under 1026.4(c)(7). The Patriot Act applies to all financial institutions and non-bank loan companies and requires entities to identify, verify and record a borrower’s identity and requires private financial information be released to the government. It is not generally a component of title insurance.
 
As it relates to New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans, finance charges are included in the high cost points and fees definition under (f)  All items listed in 15 U.S.C. § 1605(a)(1) through (4), except interest or the time-price differential.
State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

State Compliance - (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application): Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor.
These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

State Compliance - (State High Cost) New York High-Cost Loan (Points and Fees): N.Y. BNK. LAW § 6-l:
Assignee Liability:  Purchasers and assignees of New York high-cost home loans are subject to all claims and defenses with respect to the loan that the borrower could assert against the original creditor. These include (i) forfeiture of interest and costs; (ii) rendering the home loan agreement void, and (iii) rescission of the loan, with no statute of limitations when invoked as a defense to a holder's affirmative claim.  Remedies may also include actual and statutory damages or $5,000 per violation or twice the amount of points and fees and closing costs, whichever is greater, for violations of loan flipping or ability to repay requirements.

Part 41 of the General Regulations:
There is probably no assignee liability.  Lenders are subject to civil money damages and the Banking Department may take enforcement action against others who violate the regulations.   An assignee has no liability if within 60 days after discovering an error, and prior to the institution of an action under Part 41, assignee notifies individual and makes whatever adjustments are necessary to either correct the error or assure that the person will not be required to pay an amount that will make the loan subject to Part 41. Also, assignees are not liable for acts done or omitted in good faith in conformity with Banking Department regulations or provisions of the High Cost Loan Regulations that follow the federal Truth in Lending Act.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    HC - High Cost C C C C C
XXXX   3158497072   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-03-29): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158497074   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] State Compliance - Louisiana Late Charge Percent Testing: Louisiana Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-02): 4.2.24 Appeal loan closed XX/XX/XXXX with flood insurance policy pXXXX, no escrow loan and not required at that time, Notice of special Flood p129-2796 sent to borrower -Borrower had elevation certificate completed in XXXX page 69-74of2796 -D0414- kindly review resind.gs.
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains, missing disclosure from origination.
Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158485298   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material: Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
  BUYER - GENERAL COMMENT (2024-04-02): 04-02-2024  Appeal.  The lender application date is adequately supported on the Truth in Lending Input Record and Underwriting Loan Coversheet as XX/XX/XXXX. There is no lender 1003, but the application date is supported. Please see attached documents. MC
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-04): 04-04-2024  Appeal 2. Re-loading 5 page appeal document. Page 1 = Truth in Lending Input Record showing XXXX and Application date XX/XX/XXXX. Page 2 Underwriting Loan Cover Sheet showing application date is XX/XX/XXXX and underwriter name is XXXX.  Page 3-4 is XXXX Underwriting Approval showing UW name is XXXX and that she approved loan on XX/XX/XXXX. Page 5 is DU pulled by XXXX on XX/XX/XXXX.  The appilication date of XX/XX/XXXX is supported. MC
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-02): 04-02-2024  Appeal.  The lender application date is adequately supported on the Truth in Lending Input Record and Underwriting Loan Coversheet as XX/XX/XXXX. There is no lender 1003, but the application date is supported. Please see attached documents. MC
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-04): 04-04-2024  Appeal 2. Re-loading 5 page appeal document. Page 1 = Truth in Lending Input Record showing XXXX and Application date XX/XX/XXXX. Page 2 Underwriting Loan Cover Sheet showing application date is XX/XX/XXXX and underwriter name is XXXX.  Page 3-4 is XXXX Underwriting Approval showing UW name is XXXX and that she approved loan on XX/XX/XXXX. Page 5 is DU pulled by XXXX on XX/XX/XXXX.  The appilication date of XX/XX/XXXX is supported. MC
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
REVIEWER - GENERAL COMMENT (2024-04-09): Exception regraded to EV2-B.
BUYER - GENERAL COMMENT (2024-04-02): 04-02-2024  Appeal.  The lender application date is adequately supported on the Truth in Lending Input Record and Underwriting Loan Coversheet as XX/XX/XXXX. There is no lender 1003, but the application date is supported. Please see attached documents. MC
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-04): 04-04-2024  Appeal 2. Re-loading 5 page appeal document. Page 1 = Truth in Lending Input Record showing XXXX and Application date XX/XX/XXXX. Page 2 Underwriting Loan Cover Sheet showing application date is XX/XX/XXXX and underwriter name is XXXX.  Page 3-4 is XXXX Underwriting Approval showing UW name is XXXX and that she approved loan on XX/XX/XXXX. Page 5 is DU pulled by XXXX on XX/XX/XXXX.  The appilication date of XX/XX/XXXX is supported. MC
REVIEWER - GENERAL COMMENT (2024-04-08): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158497083   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158485318   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485321   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485323   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.   Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158497093   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.   BUYER - GENERAL COMMENT (2024-04-03): 4.3.24 Appeal attached Initial hand written/typed 1003 taken by telephone -AMC p58-61of1347 -D0178- GFE p92of1347 -D 0097- dated prepared printed XX/XX/XXXX  signed XX/XX/XXXX date stamped XX/XX/XXXX-all disclosures the same infile kindly review rescind.gs.
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains, application referenced is not dated and alt documents must state application date.
      - B B B B B
XXXX   3158497098   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing itemization of amount financed.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485343   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] 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).
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158485349   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUS AMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158486608   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485363   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: under disclosure due to itemization not disclosing an origination fee in the amount of $XXXX and disclosing a settlement closing fee in the amount of $1,846 and HUD disclosing a settlement closing fee in the amount of $1,150. BUYER - GENERAL COMMENT (2024-04-15): Appeal:  Attached please find the subject loan closing instructions showing the loan origination fee of $XXXX paid to lender is paid by the mortgage broker.
BUYER - GENERAL COMMENT (2024-04-15): closing instructions
REVIEWER - GENERAL COMMENT (2024-04-16): Exception remains, HUD does not list the origination fee as broker paid and no credit from broker on page 1 of HUD.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158486638   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-02): 4.2.24 Appeal page163of3755-D0802 XXXX application received date stamped XX/XX/XXXX application taken by telephone, mailed Arm disclosure dated XX/XX/XXXX page 507of3755-D0431-application disclosure dated XX/XX/XXXX page 285-of3755 D0428, Note date XX/XX/XXXX brokered loan kindly review rescind.gs.
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains.   Received stamp on broker application  not accepted alt source application date. Application date per the review XX/XX/XXXX.
BUYER - GENERAL COMMENT (2024-04-02): 4.2.24 Appeal attached your page 312of3755-D 0794 final signed TIL dated XX/XX/XXXX signed XX/XX/XXXX and p310of3755-D 0792-Initial Prelim TIL, our borrower XXXX Friday property XXXX kindly review rescind.gs.
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains.  TIL provided with appeal is dated and signed prior to closing.  Final TIL in file dated XX/XX/XXXX and signed date of closing.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158497115   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Estimated: Final TIL disclosure found in file had markings indicating one or more entries are estimates.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Federal Compliance - Final TIL Estimated: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485374   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - New York Prepayment Penalty: New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.
[2] Federal Compliance - (Missing Data) Unable to determine if loan is a same lender refi (Circuit 2, 5, 7, 8, 9, 10 or DC): Original Lender was not able to be determined. Unable to determine if correct TILA rescission form was used. (H-8 Form was used and property is in the 2 nd, 5 th, 7 th, 8 th, 9 th, 10 th, or District of Columbia)
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485380   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485384   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] 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
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485390   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Disclosed payment on note of $  does not correspond with the loan amount, loan term and interest rate on the loan.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485407   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485409   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] 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.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Conditional Loan Approval indicates the Index used by the lender was X.XX%. The Index available within the look-back period is X.XX%.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158485431   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485441   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497130   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Disparity in Occupancy - Not High Cost and Not Higher Priced: The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Investment).
[2] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-01): 4.1.24 Appeal attached page 51of792 XXXX counter offer approval shows borrower applied for as an investment property was not currently living in property at time of 1003,  locked as an investment property, page 92-95of792 Occupancy affidavit I will not occupy the property- page 147-792 -locked in as a NON-Owner/Investment. Closed as primary residence -Appraisal shows primary residence. P362of792 kindly review and rescind.gs.
REVIEWER - GENERAL COMMENT (2024-04-02): Exception remains, Page 1 of application is referencing an investment property and page 3 of application states borrower intended to occupy property as primary.
REVIEWER - GENERAL COMMENT (2024-04-09): Exception regraded to EV2-B.
      - B B B B B
XXXX   3158485447   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497132   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] 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.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158485454   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Refinance Rate/Term   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.     Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485484   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158497146   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material: Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing BUYER - GENERAL COMMENT (2024-04-02): 04/01/2024 Appeal: Please see Doc D0030. The Final HUD is signed by the Settlement Agent and marked as Certified to be a true copy. CK
REVIEWER - GENERAL COMMENT (2024-04-02): Exception remains. In a non-escrow state the Final HUD-1 must be signed by the borrower at closing
REVIEWER - GENERAL COMMENT (2024-04-09): Exception regraded to EV2-B.
      - B B B B B
XXXX   3158497148   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing. BUYER - GENERAL COMMENT (2024-04-01): 04/01/2024 Appeal: Please see DOC D0127 for the Final HUD1 which is stamped and executed by the settlement agent. CK
REVIEWER - GENERAL COMMENT (2024-04-02): Exception remains. HUD page 2 includes Funds Held and purpose not provided.
REVIEWER - GENERAL COMMENT (2024-04-09): Exception regraded to EV2-B.
      - B B B B B
XXXX   3158485506   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158485535   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - 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
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: It appears Lender used an index outside of the lookback period. the lowest Index available in our look-back is X.XX%.
BUYER - GENERAL COMMENT (2024-04-02): 4/2-Appeal: HMDA form reflects application date of XX/XX/XXXX, the CHARM Booklet was provided within 3 business days of application date on XX/XX/XXXX.
REVIEWER - GENERAL COMMENT (2024-04-02): Acknowledgement in file dated XX/XX/XXXX. Please provide document to support the XX/XX/XXXX per comment.
BUYER - GENERAL COMMENT (2024-04-03): see attached
BUYER - GENERAL COMMENT (2024-04-03): .
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains.  Missing acknowledgement of receipt of the CHARM
Disclosure from the borrower or evidence that the disclosure was sent to the borrower.
In order to be considered acceptable, an acknowledgement of receipt must be dated, confirm
receipt of the disclosure and be signed by the borrower.
BUYER - GENERAL COMMENT (2024-04-02): 4/2-Appeal: Payment on the Note dated XX/XX/XXXX is $XXXX please advise where payment of $XXXX is appearing.
REVIEWER - GENERAL COMMENT (2024-04-02): Comment updated in connection with Underdisclosed amount. Removed Disclosed payment on note of $XXXX does not correspond with the loan amount, loan term and interest rate on the loan.
BUYER - GENERAL COMMENT (2024-04-03): Appeal : Following Fees were included in the PPFC, Origination Fee $6,070.00 + Funding/Review Fee+ $355.00Tax Service +$81.00 +Wire Transfer $35.00
+ Flood Cert LOL $8.00 + Processing Fee $686.00 +File Storage Fee $59.00 + Daily Interest -$27.42(credit) +Settlement/Closing Fee $300.00 +Recording Processing Fee $30.00 +Shipping/Handling  $90.00.  Signing(Notary)Fee and Payment processing fee are not prepaid finance charges. TC
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Underdisclosure appears to be related to the payment stream variation. It appears the lender used an index lower than X.XX%%%, which is the lowest rate in the look back period. .
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158485555   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485560   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-03-29): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497165   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497170   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497171   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485604   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-03-29): Per client request.       3 [3] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.       Yes TR Indeterminable D D D D D
XXXX   3158485608   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL itemization did not disclose an Email/ E-doc of $50, Settlement fee of $245 and Wire fee of $30, Tittle Courier Fee,$120 as prepaid finance charge.
  Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158497178   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Disclosed payment on note of $XXXX does not correspond with the loan amount, loan term and interest rate on the loan.
REVIEWER - GENERAL COMMENT (2024-04-09): Exception regraded to EV2-B. Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485625   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158485627   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material: Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing BUYER - GENERAL COMMENT (2024-04-09): D0005 was stamped/signed by the settlement agent (bottom of pages 1 and 2).
REVIEWER - GENERAL COMMENT (2024-04-09): Exception regraded to EV2-B.
BUYER - GENERAL COMMENT (2024-04-09): D0005 was stamped/signed by the settlement agent (bottom of pages 1 and 2). Please review to Clear/EV1.
REVIEWER - GENERAL COMMENT (2024-04-11): Exception remains, HUD in referenced rebuttal is estimated as per line 903.
      - B B B B B
XXXX   3158497182   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158486648   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158485641   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158497184   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497186   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158485653   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] 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.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.     - B B B B B
XXXX   3158485657   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158485659   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing         - B B B B B
XXXX   3158485665   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing..         - B B B B B
XXXX   3158497192   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-03-29): Per client request.
BUYER - GENERAL COMMENT (2024-04-02): 4.2.24-Appeal Initial application page43-50-1324-D0075 (2copies) signed by borrowers and LO was all that was required in XX/XX/XXXX Note date XX/XX/XXXX kindly advise.gs
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Missing Final 1003 Application.
      2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158485675   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158497198   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Refinance Rate/Term   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disparity in Occupancy - Not High Cost and Not Higher Priced: The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Second Home).
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485680   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] 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.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - TILA - Incorrect Right To Cancel Form Used - H-8 Used on Same Lender Refinance (Third Circuit): TILA ROR Form - The Third Circuit has prior rulings that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form. Creditors are required to use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158485683   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] 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.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158497205   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485708   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-03-29): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158485713   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] 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.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158485728   XXXX XXXX $XXX XX XX/XX/XXXX Second Home Purchase   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.     Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485775   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485786   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497218   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485800   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.     - B B B B B
XXXX   3158485806   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158486708   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158485821   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485825   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] 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.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158497225   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] Federal Compliance - Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing: FDPA Notification Rule: Creditor did not retain record of borrower's receipt of Notice of Special Flood Hazard Disclosure.
[2] Miscellaneous Compliance - Alternate source used for application date
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - Acknowledgement of Borrower Receipt of Notice of Special Flood Hazard Disclosure Missing: Liability for violations cannot be transferred to a subsequent purchaser of a loan.     - B B B B B
XXXX   3158485836   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] State Compliance - New Jersey Prepayment Penalty: New Jersey Prepayment Penalty: No prepayment penalties are permissible in the state of New Jersey. Prepay language states prepay will not exceed maximum permitted by applicable law.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485842   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.
[2] 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.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] State Compliance - Illinois Prepayment Penalty: Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
[2] 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.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

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): TILA ROR Form - Because this issue is not uniformly settled among the circuit courts, the continuing risk that the borrower may have an extended right to rescind (3 additional years) if a creditor uses the incorrect Model Form remains. Because of this uncertainty, we continue to recommend that creditors use Model Form H-8 only for refinances involving a new creditor and Model Form H-9 for refinances involving the same creditor.
    - B B B B B
XXXX   3158485871   XXXX XXXX $XXX XX XX/XX/XXXX Investment Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158486718   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158485874   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485885   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Miscellaneous Compliance - Alternate source used for application date Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485887   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-03-29): Per client request.
BUYER - GENERAL COMMENT (2024-04-03): 4.3.24 Appeal-borrower was not at closing had a AttorneyInFact-POA sign Note date XX/XX/XXXX,
Attached final loan application signed-wet signature by borrower and marked “final” XX/XX/XXXX -AMC file page26of2491- D 0429. Attached initial 1003 stamp received date XX/XX/XXXX.AMC accepting broker now.kindly review and rescind.gs
BUYER - GENERAL COMMENT (2024-04-03): part 2.
BUYER - GENERAL COMMENT (2024-04-03): 4.3.24 Please cancel this appeal request. Thank you gs.
REVIEWER - GENERAL COMMENT (2024-04-03): No action appeal cancelled
      2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158497237   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Flood Certificate not provided   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.         - B B B B B
XXXX   3158485897   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
    Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158485898   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.
BUYER - GENERAL COMMENT (2024-04-11): 4-11-24 APPEAL, Providing final Addendum to loan application.  /dp
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, missing final 1003
      2 [2] Miscellaneous Compliance - (Doc Error) RTC Error:  Right to Cancel expiration date is blank.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
[2] Federal Compliance - TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date: Unable to test RTC expiration date due to missing information.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine under disclosure due to missing Itemization of Amount Financed.   Miscellaneous Compliance - (Doc Error) RTC Error:  Right to Cancel expiration date is blank.: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.

Federal Compliance - TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158497239   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-02): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158497247   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-03-29): Per client request.
BUYER - GENERAL COMMENT (2024-04-02): 04-02-2024  Appeal.  In 2023 AMC had agreed to accept the Broker's Final 1003 as the final 1003.  The Lenders 1003 was not required as pertains to the Final 1003. Acuity contains the brokers initial and final 1003s and both are stamped for identification.  Has this policy changed?  It is acknowledged that there are no Lender 1003s in the loan file, only Broker 1003s are present.  Pleasee advise, thank you.  MC
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Reviewed Broker with a stamp Final with reference to comments. Document provided is not signed by the borrower(s).
      2 [2] Federal Compliance - Federal FACTA Disclosure Timing Test: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL Itemization did not disclose a Settlement fee $1,500.00  as prepaid finance charge.
Over disclosure of finance charge is due to TIL payment stream
BUYER - GENERAL COMMENT (2024-04-01): 04-01-2024  Appeal.  AMC LASR is including  the ($750 HUD1 line 1301) survey fee in PPFCs which should be excluded. Please review and advise. AMC notes mention a $1,500 settlement fee that was not included. Lender was unable to locate this fee on the HUD1. Please specify by HUD1 line number if this is insufficient to resolve. MC
REVIEWER - GENERAL COMMENT (2024-04-02): Exception remains, under disclosure is due to TIL itemization disclosed a settlement closing fee in the amount of $1,500 ( which seems to be all the prepaid finance charge title charges) Total of title prepaid finance charges is $1,514.97. ($14.97 not disclosed on itemization) Application fee in the amount of $495.00 should be included in prepaid finance charges but not. Survey fee not included in prepaid finance charge calculation.
BUYER - GENERAL COMMENT (2024-04-03): 04-03-2024 2nd Appeal. Please note, AMC LASR shows a $750 fee listed in PPFCs which is shown as an attorney fee.  The only $750 fee listed on the HUD1 is for the Survey fee on line 1301. This should be excluded from PPFCs.  The itemization is not adding fees adding fees to the HUD1; it seems to be re-grouping them and has an "E" next to them.  The PPFCs should be taken from the HUD1. Please review and advise. MC
REVIEWER - GENERAL COMMENT (2024-04-04): Exception remains, Attorney fee is charged on line 1107 in the amount of $750.00.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158486004   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-03-29): Per client request.       2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Closing / Title - (Doc Error) TIL Error: Final TIL not signed by all required parties
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Closing / Title - (Doc Error) TIL Error: Final TIL not signed by all required parties: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158486014   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   3             3 [3] Federal Compliance - Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material: Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.
[2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-02): See 1003 upload, pls cclear
REVIEWER - GENERAL COMMENT (2024-04-02): Document provided is Broker initial application. Alt source of app date was approved by client for loans missing Lender Initial application date. Exception remains.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
  Yes TR HUD Deficiency D D D D D
XXXX   3158486021   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158497255   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2 [2] Insurance Documentation - Flood Insurance Error: Policy number is not provided.           2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158486033   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158486042   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] 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.     Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158486044   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing: Unable to test Affiliated Business Disclosure due to missing information.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
  BUYER - GENERAL COMMENT (2024-04-01): 4-1-24 APPEAL, providing evidence of Application Date. /dp
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-01): 4-1-24 APPEAL, providing evidence of Application Date. /dp
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
BUYER - GENERAL COMMENT (2024-04-01): 4-1-24 APPEAL, providing evidence of Application Date. /dp
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158486048   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.           - B B B B B
XXXX   3158486054   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-02): Please see Pg 41 to 43 Pg0057 Initial 1003 dated and signed XX/XX/XXXX taken in person states page 4 missing there is nothing on page government monotoring is on page 3.
BUYER - GENERAL COMMENT (2024-04-02): Correction Initial 1003 signed and dated XX/XX/XXXX
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158497262   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
  BUYER - GENERAL COMMENT (2024-04-02): 4/2/2024: Appeal. Please find GFE (Good Faith Estimate) in Clarity doc # D0029. Just above the borrower's signature, a checked marked that disclosure included ARM loan program disclosure and was acknowledged received by the borrower. LL
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains, Missing ARM disclosure from loan file. GFE is referencing Consumer handbook on ARM mortgages.
Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158497263   XXXX XXXX $XXX XX XX/XX/XXXX Investment Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.           - B B B B B
XXXX   3158486738   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
    Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158497266   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Final HUD-1:  Illegible HUD-1 Used For Fee Testing Material: Missing Final HUD-1: Illegible HUD-1 used for any applicable Federal, State or Local compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  REVIEWER - GENERAL COMMENT (2024-04-09): Regraded to EV2-B. Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158497267   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   3             3 [3] Federal Compliance - Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material: Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.
[2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
  Yes TR Indeterminable D D D D D
XXXX   3158486067   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158486073   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL itemization did not disclose an Attorney fee of $450 and Title Courier Fee of $25 as prepaid finance charge.   Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158497272   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-03): Appeal:  Attached please find the initial 1003 with the loan officer signature and date showing application taken XX/XX/XXXX and signed as final at close on XX/XX/XXXX.
BUYER - GENERAL COMMENT (2024-04-03): initial 1003
REVIEWER - GENERAL COMMENT (2024-04-03): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003.
      - B B B B B
XXXX   3158486084   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] State Compliance - New York Late Charge Percent Testing: New York Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 2%.
[2] State Compliance - New York Prepayment Penalty: New York Prepayment Penalty: Maximum prepay term allowed on a loan with an interest rate greater than 6% is 12 months.  Loan with an interest rate of X.XX% contracts for a prepay term of 24 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.
          - B B B B B
XXXX   3158486086   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2 [2] Application / Processing - Flood Certificate Error: Certificate Number was not provided.           2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
          - B B B B B
XXXX   3158486093   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TIL Itemization did not disclose a Settlement/Escrow /Closing $700.00 as prepaid finance charge.   Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158486109   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
  BUYER - GENERAL COMMENT (2024-04-16): 4-16-24 APPEAL, Providing evidence of Lender’s initial application disclosure to the borrower.  /dp
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.
      - B B B B B
XXXX   3158486112   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA
    - B B B B B
XXXX   3158486115   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.
    - B B B B B
XXXX   3158497285   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] Miscellaneous Compliance - Alternate source used for application date
[2] 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.
[2] Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Miscellaneous Compliance - Alternate source used for application date: At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Under disclosure due to TIL disclosed utilizing an index lower than available within look back. Lowest index within look back is X.XX%.
  Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
    - B B B B B
XXXX   3158486120   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   2             2 [2] 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.     Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158486125   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other   2 [2] Application / Processing - Missing Document: Missing Final 1003   REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.       2 [2] Federal Compliance - ARM Disclosure Status Test: TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.
[2] Federal Compliance - CHARM Booklet Disclosure Status: TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.
[2] Federal Compliance - FACTA Disclosure Missing: FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.
    Federal Compliance - ARM Disclosure Status Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Status: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - FACTA Disclosure Missing: There is no Assignee Liability.
    - B B B B B
XXXX   3158497288   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] 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.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.
  BUYER - GENERAL COMMENT (2024-04-11): 04-11-2024  Appeal.  Please see attached Acknowledgment letter signed by the borrower. ABA was mailed on XX/XX/XXXX and application date was XX/XX/XXXX. Trailing docs 11:16 AM.  MC
REVIEWER - GENERAL COMMENT (2024-04-15): Exception remains, missing aba from application date from loan file.
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158486139   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase   2             2 [2] 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.     Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA     - B B B B B
XXXX   3158486141   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Debt Consolidation   2             2 [2] Federal Compliance - ARM Disclosure Timing Test: Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.
[2] Federal Compliance - CHARM Booklet Disclosure Timing: Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.
[2] Federal Compliance - Missing Initial Loan Application Test: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.
[2] Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.
[2] Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.
  BUYER - GENERAL COMMENT (2024-04-17): Appeal. The loan file contain a letter from Lender  at pg 90/1264 D 0214 that the Disclosure Acknowledgements were mailed see issued date XX/XX/XXXX which should establish ABAD was provided to the customer within 3 days of application.
REVIEWER - GENERAL COMMENT (2024-04-18): Letter does not include a copy of the ABA  for review. Exception remains..
Federal Compliance - ARM Disclosure Timing Test: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - CHARM Booklet Disclosure Timing: TILA - subject to a 1 year SOL for affirmative claims under TILA

Federal Compliance - RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date: TILA ROR - 3yrs for rescindable transactions.
    - B B B B B
XXXX   3158497292   XXXX XXXX $XXX XX XX/XX/XXXX UTD UTD UTD   3 [2] Application / Processing - Missing Document: Flood Certificate not provided
[2] Application / Processing - Missing Document: Missing Final 1003
  REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
REVIEWER - GENERAL COMMENT (2024-04-05): Per client request.
      3 [3] Federal Compliance - Missing Final HUD-1:  No Document Used For Fee Testing Material: Missing Final HUD-1.  No document containing fees provided.  Any applicable Federal, State or Local compliance testing is unreliable.
[2] Federal Compliance - Disbursement Date Missing Test: Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.
[2] General Appraisal Requirements - Due to lack of appraised value, compliance tests requiring an LTV were run off an assumed value of a contract sales price or original loan amount, whichever applies.
[2] Miscellaneous Compliance - (Doc Error) Initial GFE not provided
[2] Federal Compliance - Missing Initial Loan Application No Fees: No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation.  A lookback was performed to determine this application date. Due to missing HUD-1 or Closing Disclosure, no fees were used in testing.
[2] Federal Compliance - Property Type Not Provided: (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.
[2] Federal Compliance - Notice of Right to Cancel Missing: Truth in Lending Act: Notice of Right to Cancel was not provided.
[2] Federal Compliance - TILA - Final TIL Missing: Missing Final TIL.
[2] Miscellaneous Compliance - Unable to determine occupancy, compliance results were generated using a defaulted value of Primary.
  BUYER - GENERAL COMMENT (2024-04-17): Appeal. Please see D0859. According to Special Transfer/Assumption Rider to Mortgage subject property satisfy the URA requirement for URA's XXXX Home Ownership Program Single Family Mortgage Revenue Bonds.
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, Unable to determine specific property type at origination.
BUYER - GENERAL COMMENT (2024-04-17): Appeal. Please see D0377 and D0343. Dataverify and XXXX Agent Desktop confirmed property occupancy.
REVIEWER - GENERAL COMMENT (2024-04-17): Exception remains, Post origination documentation referenced for occupancy, Unable to determine occupancy at origination.
Federal Compliance - Notice of Right to Cancel Missing: TILA ROR - 3yrs for rescindable transactions.

Federal Compliance - TILA - Final TIL Missing: TILA - 1yr affirmative, 3yrs for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.
  UTD Indeterminable D D D D D
XXXX   3158496865   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase Temporary SHQM (GSE/Agency Eligible) 2             2 [2] Federal Compliance - RESPA (2010) - 10% Tolerance Without Cure: RESPA (2010): 10% tolerance violation without  evidence of sufficient cure provided.
[2] Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: RESPA (2010):  GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.
[2] Federal Compliance - RESPA (2010) – Written Service Provider List Not Provided Timely: RESPA (2010) - Borrower did not receive a list of service providers at the time the Good Faith Estimate was provided.
[2] Federal Compliance - RESPA Disclosure -  HUD Settlement Cost Booklet Missing: RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet.
Federal Compliance - RESPA (2010) - 10% Tolerance Without Cure: 10% tolerance violation without  evidence of sufficient cure provided.
Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.
Federal Compliance - RESPA (2010) – Written Service Provider List Not Provided Timely: List of service providers was provided on XX/XX/XXXX, not at the time the Good Faith Estimate was provided XX/XX/XXXX.
Federal Compliance - RESPA Disclosure -  HUD Settlement Cost Booklet Missing: Creditor did not provide HUD Settlement Cost Booklet.
  Federal Compliance - RESPA (2010) - 10% Tolerance Without Cure: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA (2010) – Written Service Provider List Not Provided Timely: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure -  HUD Settlement Cost Booklet Missing: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158496866   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase Temporary SHQM (GSE/Agency Eligible) 2             2 [2] Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: RESPA (2010):  GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.
[2] Federal Compliance - RESPA Disclosure -  HUD Settlement Cost Booklet Missing: RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet.
Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.   Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA Disclosure -  HUD Settlement Cost Booklet Missing: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158496867   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term Temporary SHQM (GSE/Agency Eligible) 1             1             - A A A A A
XXXX   3158484873   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term Safe Harbor QM 2             2 [2] Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX)
[2] Federal Compliance - QM Employment History - Current and/or Previous Employment Documentation lacks Date Info: Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years employment history for current and/or prior employment. (XXXX/XXXX/XXXXX)
[2] Federal Compliance - Final TIL Finance Charge Under Disclosed: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.
Federal Compliance - QM Employment History - Current and/or Previous Employment Documentation lacks Date Info: A copy of the DU findings is missing which caused the loan to test to standard QM requirements.
Federal Compliance - Final TIL Finance Charge Under Disclosed: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.
BUYER - GENERAL COMMENT (2024-04-04): 4/5/2024 Appeal: Please see DOC D0329. The borrower was informed on XX/XX/XXXX that they would receive a copy of any appraisal, even if the loan does not close. CK
REVIEWER - GENERAL COMMENT (2024-04-09): Evidence that the Appraisal was provided to the Borrower is missing.
Federal Compliance - Final TIL Finance Charge Under Disclosed: TILA Finance Charge - subject to a 1 year SOL for affirmative claims, 3 years for rescindable transactions.  Unlimited as a defense to foreclosure. Assignee liability.     - B B B B B
XXXX   3158484877   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase Temporary SHQM (GSE/Agency Eligible) 2             2 [2] Federal Compliance - RESPA (2010) -  Existence of Escrow Account on Final GFE Inaccurate: RESPA (2010): Existence of escrow account disclosed on Final GFE does not match actual terms. Federal Compliance - RESPA (2010) -  Existence of Escrow Account on Final GFE Inaccurate: Existence of escrow account disclosed on Final GFE does not match actual terms.   Federal Compliance - RESPA (2010) -  Existence of Escrow Account on Final GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158496879   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term Temporary SHQM (GSE/Agency Eligible) 2             2 [2] Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX)
[2] Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (2010): Loan Amount on Final GFE does not match Note.
[2] Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (2010): Initial payment on GFE does not match actual payment on loan.
Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: The final GFE provided on XX/XX/XXXX disclosed on page 1 an incorrect loan amount and principal and interest loan payment.
Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: The initial GFE provided on XX/XX/XXXX disclosed on page 1 an incorrect loan amount and principal and interest loan payment. No change of circumstance provided to the borrower.
  Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158496880   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Cash-out - Other Safe Harbor QM 3 [3] AUS Discrepancy / Guidelines Discrepancy - AUS/Guideline Findings: All conditions were not met
[3] Application / Processing - Missing Document: AUS not provided
Missing a copy of the DU findings.
The Zippy findings and 1008 reflect loan was DU approved, but a copy of the DU findings is missing.  The 1008 and Zippy were used for loan review.
BUYER - GENERAL COMMENT (2024-04-04): 4.4.24 Appeal.  Please specify what conditions were not satisfied in the AUS.  The AUS is already found in the loan file beginning on page D0733.  Please review and rescind. rk
REVIEWER - GENERAL COMMENT (2024-04-09): The DU findings provided were submitted XX/XX/XXXX.  It appears the final DU submission is missing.  There are Zippy submissions dated XX/XX/XXXX.   Additionally, the DU provided is missing the last page.
BUYER - GENERAL COMMENT (2024-04-11): 4.11.24 Appeal.  Please see attached the complete Underwriting Approval for this loan which includes, Zippy Approval, DU Approval, 1008, and Underwriting Approval based off Zippy.  All underwriting approval documentation is provided.  Please review and rescind. rk
REVIEWER - GENERAL COMMENT (2024-04-11): The most recent Zippy shows DU approved XX/XX/XXXX.  The DU findings in the loan file were submitted XX/XX/XXXX and is missing pages.  The final DU submission is required.
BUYER - GENERAL COMMENT (2024-04-04): 4.4.24 Appeal.  The AUS was provided in the loan file and can be found beginning on page D0733.  Please review and rescind. rk
REVIEWER - GENERAL COMMENT (2024-04-09): The DU findings provided were submitted XX/XX/XXXX.  It appears the final DU submission is missing.  There are Zippy submissions dated XX/XX/XXXX.   Additionally, the DU provided is missing the last page.
BUYER - GENERAL COMMENT (2024-04-11): 4.11.24 Appeal.  Please see attached the complete Underwriting Approval for this loan which includes, Zippy Approval, DU Approval, 1008, and Underwriting Approval based off Zippy.  All underwriting approval documentation is provided.  Please review and rescind. rk
REVIEWER - GENERAL COMMENT (2024-04-11): The most recent Zippy shows DU approved XX/XX/XXXX.  The DU findings in the loan file were submitted XX/XX/XXXX and is missing pages.  The final DU submission is required.
      3 [3] Federal Compliance - Check Loan Designation Match - QM: Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Safe Harbor QM.
[2] Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX)
[2] Federal Compliance - RESPA (2010) -  Interest Rate on GFE Inaccurate: RESPA (2010): Interest Rate on GFE does not match Note.
[2] Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (2010): Initial payment on GFE does not match actual payment on loan.
Federal Compliance - Check Loan Designation Match - QM: Loan is non agency salable causing loan to waterfall to designation of safe harbor QM.
Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: A copy of appraisal was not provided three days prior to closing.
Federal Compliance - RESPA (2010) -  Interest Rate on GFE Inaccurate: Interest Rate on GFE X.XX% does not match Note X.XX%.
Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: Initial payment on GFE $XXXX does not match actual payment on loan of $XXXX.
  Federal Compliance - Check Loan Designation Match - QM: Rating Agency requirements are to have the Creditor provide the ATR/QM Loan Designation to the TPR firm performing the loan level due diligence and to have the TPR firm confirm said designation.

Federal Compliance - RESPA (2010) -  Interest Rate on GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    TILA ATR/QM C C B B B
XXXX   3158496952   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term Safe Harbor QM 2             2 [2] Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX)
[2] Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX)
[2] Miscellaneous Compliance - (Doc Error) GFE Error: Changed Circumstance not provided.: GFE Date: XX/XX/XXXX, GFE Date: XX/XX/XXXX, GFE Date: XX/XX/XXXX Changed Circumstance not provided for GFE dated XX/XX/XXXX from GFE dated XX/XX/XXXX
Changed Circumstance not provided for GFE dated XX/XX/XXXX from GFE dated XX/XX/XXXX
Changed Circumstance not provided for GFE dated XX/XX/XXXX from GFE dated XX/XX/XXXX
Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: A copy of appraisal was not provided three business days prior to closing.
Federal Compliance - ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation: Creditor did not provide a copy of each valuation to applicant three business days prior to consummation.
Miscellaneous Compliance - (Doc Error) GFE Error: Changed Circumstance not provided.: Changed Circumstance not provided.
    Borrower has been employed in the same industry for more than 5 years.

Borrower has owned the subject property for at least 5 years.

Borrower has verified disposable income of at least $2500.00.

Borrower has worked in the same position for more than 3 years.

The Loan to Value (LTV) on the loan is less than or equal to XX%.
  - B B B B B
XXXX   3158497036   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term Safe Harbor QM 2             2 [2] Federal Compliance - ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely: ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status. Federal Compliance - ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely: Right to Receive a Copy Appraisal is required to be delivered to borrower within 3 business days from application date.   Federal Compliance - ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely: There is generally no Assignee Liability.     - B B B B B
XXXX   3158497037   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term Temporary SHQM (GSE/Agency Eligible) 2             2 [2] Federal Compliance - TILA NMLSR - Individual Originator License Status Not Approved: Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not licensed to conduct loan origination activities.
[2] Federal Compliance - TILA NMLSR - Individual Originator NMLS information on documents does not match NMLS website: Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator NMLSR information on loan documents does not match NMLSR.
[2] Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: RESPA (2010):  GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.
Federal Compliance - TILA NMLSR - Individual Originator License Status Not Approved: Individual Loan Originator not licensed to conduct loan origination activities.
Federal Compliance - TILA NMLSR - Individual Originator NMLS information on documents does not match NMLS website: Individual Loan Originator NMLSR information on loan documents does not match NMLSR.
Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: GFE provided on XX/XX/XXXX does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.
  Federal Compliance - TILA NMLSR - Individual Originator NMLS information on documents does not match NMLS website: Assignee Liability:  Civil actions that may be brought against a creditor may be maintained against any assignee only if the violation is apparent on the face of the disclosure or other documents assigned, except where the assignment was voluntary.  This civil liability may include $4,000, in the case of an individual transaction, or the lesser of $500,000 or 1% of the creditor's net worth in the case of a class action (effective 1/10/14, this amount increases to the lesser of $1,000,000 or 1%), as well as actual damages, court costs, and attorneys' fees.  For an anti-steering violation, the creditor may also be liable in an amount equal to the sum of all finance charges and fees paid by the consumer, unless the creditor demonstrates the failure to comply is not material.  Notwithstanding any other provision of law, when a creditor, assignee, or other holder or anyone acting on behalf of the creditor, assignee, or holder, initiates a judicial or nonjudicial foreclosure of the residential mortgage loan, or any other action to collect the debt in connection with such loan, a consumer may assert a violation as a matter of defense by recoupment or set off without regard for the time limit on a private action for damages.
Effective 1/10/2014 in addition to the aforementioned, the individual Loan Originator could be liable for statutory damages. The maximum liability is the greater of actual damages or 3 times the loan originator's compensation or gain, plus the cost to the consumer of the action. The Dodd-Frank Act extended the statute of limitations on TILA violations to 3 years from the date of the violation.

Federal Compliance - RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158497038   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term Temporary SHQM (GSE/Agency Eligible) 1             1             - A A A A A
XXXX   3158497039   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase Safe Harbor QM 2             2 [2] Federal Compliance - RESPA Disclosure -  HUD Settlement Cost Booklet Missing: RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. Federal Compliance - RESPA Disclosure -  HUD Settlement Cost Booklet Missing: Creditor did not provide HUD Settlement Cost Booklet.   Federal Compliance - RESPA Disclosure -  HUD Settlement Cost Booklet Missing: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.     - B B B B B
XXXX   3158497040   XXXX XXXX $XXX XX XX/XX/XXXX Primary Purchase Temporary SHQM (GSE/Agency Eligible) 2             2 [2] Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (2010): Loan Amount on Final GFE does not match Note.
[2] Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (2010): Initial payment on GFE does not match actual payment on loan.
    Federal Compliance - RESPA (2010) -  Loan Amount on Final GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.

Federal Compliance - RESPA (2010) -  Initial Payment on GFE Inaccurate: RESPA (Sections 4 and 5) contains no explicit assignee liability provisions within the statute or implementing regulation, Regulation X, for these type of violations.
    - B B B B B
XXXX   3158497044   XXXX XXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term Safe Harbor QM 1             1             - A A A A A

 

 
 
                                                         
Exception Ratings                                                          
                                                           
AMC Loan ID Customer Loan ID Alternate Loan ID Seller Loan ID Loan Exception ID Exception ID Exception Date Exception Type Exception Category Exception Subcategory 15E Category Exception Exception Detail Exception Information Compensating Factors Follow-up Comments Cleared Date Unable To Clear Date Cured Date Waived Date Exception Level Grade Note Date Property State Occupancy Purpose Exception Remediation DBRS Final Exception Rating Fitch Final Exception Rating Kroll Final Exception Rating Moody's Final Exception Rating S&P Final Exception Rating Originator QM ATR Status TPR QM ATR Status Is Curable Overal Final  Loan Grade
XXXX   3158496239   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496239   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496239   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496239   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Connecticut Prepayment Penalty Test Connecticut Prepayment Penalty: A prepayment penalty is not permissible under the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.     Reviewer Comment (2024-04-16): The exemption from the prepayment penalty restriction established in the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act is not a blanket exemption for all mortgage brokers. The mortgage broker or mortgage lender must meet one of the exemptions from licensure established in Section 36a-487 of the Act.  While XXXX meets exemption under 36a-487(a)(1), it is not clear if the lender in the request meet any of the exemptions listed in this section. Please provide information about how each of the lenders meets ones of the exemptions listed in Section 36a-487. Exception remains.


Buyer Comment (2024-04-10): Cited prohibition is applicable to a mortgage broker. Prepayment penalty is payable to XXXX which is the lender per Sec. 36a-485. (Formerly Sec. 36-440). Definitions. (19).
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496239   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496239   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496239   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL itemization did not disclose Subordination recording fee $15 and Title Courier fee $30 as prepaid finance charge             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496239   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158496242   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No C
XXXX   3158496242   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect Federal HOEPA Ability to Repay Reliable Documentation Truth in Lending Act (HOEPA): Borrower’s ability to repay not verified with reliable documentation.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No C
XXXX   3158496242   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee) Truth in Lending Act (HOEPA): Required Statement was not provided to purchaser or assignee for loan that was sold or assigned. (Note: This notice only applies when selling or assigning a HOEPA loan and may not be found in the file for loans that have not been previously sold)               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No C
XXXX   3158496242   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided) Truth in Lending Act (HOEPA):  HOEPA disclosure was not provided to the Borrower               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No C
XXXX   3158496242   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Federal Defect (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) Truth in Lending Act (HOEPA): Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of X.XX% of the Federal Total Loan Amount and $XXXX XXXX. Points and Fees of $XXXX on a Federal Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.     Reviewer Comment (2024-04-04): Exception remains. The $180 doc prep fee is paid to the lender, so it is included as part of the total loan amount calculation.  When the doc prep fee is missing payee on HUD, our default is to test it as paid to lender. However, in this file, the Itemization of Amount Financed confirms the doc prep fee payee is the lender.


Buyer Comment (2024-04-03): Appeal:  The Federal Total Loan amount would not include the $180 Doc Prep fee which is not a prepaid finance charge under reg z and therefore the 8% threshold is $XXXX with a points and fees total of $XXXX.
        3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No C
XXXX   3158496242   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No C
XXXX   3158496242   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes C
XXXX   3158496242   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No C
XXXX   3158482734   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496250   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482754   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-08): No action, comment initial 1003 on a final 1003 exception.


Buyer Comment (2024-04-05): initial 1003


Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158482754   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.     Reviewer Comment (2024-04-08): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.


Buyer Comment (2024-04-05): ABA
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482754   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Ohio Prepayment Penalty Ohio Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 1% of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482754   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-08): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.


Buyer Comment (2024-04-05): initial 1003
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496251   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496251   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.     Reviewer Comment (2024-04-16): Exception remains, missing disbursement date from loan file to determine timing.


Buyer Comment (2024-04-15): Please see signed TIL page 75 DO551 also please see RTC page 234 D0038 signed XX/XX/XXXX Borrower signed on a Saturday which is a working day and 3 days midnight on Wednesday XX/XX/XXXX. I have enclosed a calendar for your verification
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496251   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496253   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496253   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect West Virginia Prepay Penalty West Virginia Prepayment Penalty: Loan prepay term of 60 months exceeds state maximum of 36 months.   Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496253   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482765   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect (Fed High Cost Provision) Federal High-Cost Mortgage Loan (ATR - FIR Not Used on ARM Loan) Truth in Lending Act (HOEPA):  Fully-indexed rate not used to determine ability to repay on ARM loan.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect Federal HOEPA Ability to Repay Reliable Documentation Truth in Lending Act (HOEPA): Borrower’s ability to repay not verified with reliable documentation.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee) Truth in Lending Act (HOEPA): Required Statement was not provided to purchaser or assignee for loan that was sold or assigned. (Note: This notice only applies when selling or assigning a HOEPA loan and may not be found in the file for loans that have not been previously sold)               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided) Truth in Lending Act (HOEPA):  HOEPA disclosure was not provided to the Borrower               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Federal Defect (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) Truth in Lending Act (HOEPA): Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of X.XX% of the Federal Total Loan Amount and $XXXX XXXX. Points and Fees of $XXXX on a Federal Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Ohio Prepayment Penalty Ohio Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 1% of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure is due lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496255   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No C
XXXX   3158482778   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Missing Document: Mortgage Insurance Certificate (MIC) not provided       Reviewer Comment (2024-04-08): No action


Buyer Comment (2024-04-05): 4/5/2024 Unable to locate Mortgage Insurance Certificate. JF


Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158482778   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided       Reviewer Comment (2024-04-08): No action


Buyer Comment (2024-04-05): 4/5/2024 Unable to locate initial GFE. JF
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158482778   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-08): No action


Buyer Comment (2024-04-04): 4/4/2024 Unable to locate initial lender 1003. JF
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158482778   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.     Reviewer Comment (2024-04-08): No action


Buyer Comment (2024-04-04): 4/4/2024 Unable to locate ARM loan program disclosure. JF
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158482778   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.     Reviewer Comment (2024-04-08): No action


Buyer Comment (2024-04-04): 4/4/2024 Unable to locate Charm Booklet. JF
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158482778   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.     Reviewer Comment (2024-04-08): No action


Buyer Comment (2024-04-04): 4.4.24  Unable to locate Final TIL. JF
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496260   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496260   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496260   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. The Flood Zone was determined on XX/XX/XXXX as per Flood Certificate hence the Lender provided Notice to Borrower for property being in flood hazard zone on XX/XX/XXXX which is less than 10 business days from the Note date.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482793   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Kansas Prepayment Penalty Kansas Prepayment Penalty:  Loan contains an impermissible prepayment penalty of greater than 6 months.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482809   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158482809   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482809   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Note Interest Accrual Start Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482809   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Oregon Prepayment Penalty Max Prepay Oregon Prepayment Penalty: Loan agreement or Note does not clearly state the maximum prepayment penalty applicable to each year of the loan.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496271   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158496271   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496271   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496271   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496271   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496271   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496271   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496275   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Ohio Prepayment Penalty Ohio Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 1% of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496275   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496277   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496277   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Louisiana Prepayment Penalty Louisiana Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% (in Years 1-5).  Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%,   which exceeds the max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496277   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.     Reviewer Comment (2024-04-15): Exception remains, It is unclear whether or not the previous loan included permanent financing. There is not enough information to determine whether the previous loan was construction-only or construction-permanent. Based on SitusAMC’s discussion with outside counsel, if the subject transaction refinanced permanent financing, it would be considered a standard refinance as opposed to a residential mortgage transaction and would therefore be subject to rescission. If the borrower was not obligated on permanent financing prior to subject transaction, please provide Note/HUD from prior transaction(s) or other evidence that loan(s) being satisfied were the initial construction only and that the borrower was not obligated on an existing permanent phase financing. Otherwise, a refinance of an existing permanent phase Note would make the subject transaction a refinance subject to rescission. Also just wanted to point out this exception is an EV-2.


Buyer Comment (2024-04-11): Please see page 32 D0720 Approval shows purpose Construction Perm also look at Appraisal Page 999 D0650 shows current owner XXXX XXXX. Right to cancel documentation does not apply
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496277   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496279   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496279   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided) Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Michigan Prepayment Penalty Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.   Reviewer Comment (2024-04-11): Exception remains, rounding per Note is 0.125% and missing index utilized for disclosed TIL.


Buyer Comment (2024-04-05): 4-5-24 APPEAL, Please check rounding for FIR.  Per note it is nearest .125 but LAS is showing FIR in Finance Charge chart as 7.570 which corresponds to .001.  /DE
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158482850   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty) Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 60 days interest on the unpaid principal balance.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 2% of the unpaid principal balance of the loan. Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.     Reviewer Comment (2024-04-08): Exception remains, Notary date on recorded security instrument is 0XX/XX/XXXX.


Buyer Comment (2024-04-04): 04-04-2024  Appeal.  Please clarify nature of exception. Subject RTC is dated Monday XX/XX/XXXX as transaction date and Thursday XX/XX/XXXX as close of rescsission.  HUD1 shows funding date on Friday XX/XX/XXXX. The mortgage is notarized on the transaction date as XX/XX/XXXX. All dates appear proper. Please clarify details of conflict.  MC
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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 (2024-04-08): Exception remains, Notary date on recorded security instrument is 0XX/XX/XXXX.


Buyer Comment (2024-04-04): 04-04-2024  Appeal.  Please clarify nature of exception. Subject RTC is dated Monday XX/XX/XXXX as transaction date and Thursday XX/XX/XXXX as close of rescsission.  HUD1 shows funding date on Friday XX/XX/XXXX. The mortgage is notarized on the transaction date as XX/XX/XXXX. All dates appear proper. Please clarify details of conflict.  MC
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158482859   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482860   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided       Reviewer Comment (2024-04-09): no action


Buyer Comment (2024-04-08): 4/8/2024 Unable to locate initial GFE after reviewing EIV and Acuity. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482860   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA 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.     Reviewer Comment (2024-04-09): No action


Buyer Comment (2024-04-08): 4/8/2024 Unable to locate ABA disclosure dated within 3 business days of application after reviewing EIV and Acuity. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482860   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Illinois Late Charge Percent Testing Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482860   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482860   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-09): No action


Buyer Comment (2024-04-08): 4/8/2024 Unable to locate ARM loan program disclosure after reviewing EIV and Acuity. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482860   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-09): No action


Buyer Comment (2024-04-08): 4/8/2024 Unable to locate Consumer Handbook on ARM, CHARM Booklet, provided to borrower within 3 days of application after reviewing EIV and Acuity. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482860   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482869   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482869   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA 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.     Reviewer Comment (2024-04-08): Exception remains, missing affiliated business disclosure from XX/XX/XXXX.


Buyer Comment (2024-04-04): 4/4/2024: Appeal: Please reference page 1272 Doc Code 0217 and page 6524 / 7487 no Doc Code for the Welcome Letter pages 1 and 2 dated XX/XX/XXXX which reflects the ABA disclosure was an enclosed disclosure. Also, pages 1265 & 1266 Doc Code 0665 reflects the ABA disclosure with the date on page 2. ABA date of XX/XX/XXXX is with 3 days Application Date XX/XX/XXXX. LM
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482875   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158482875   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158482880   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158482880   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482880   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482883   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158482883   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482893   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158482893   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158482893   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496298   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is.X.XX%.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158482900   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482900   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482900   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482900   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482900   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482907   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482907   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482907   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158482907   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482910   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Georgia Home Loan (Late Charge) Georgia Home Loan:  Mortgage loan contains an impermissible late charge of greater than 5.0% or a grace period of less than ten (10) days.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482910   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure unable to find due to itemizaton is missing.   Reviewer Comment (2024-04-08): Exception remains.  Interest captured per HUD i/a/o $47.04.


Buyer Comment (2024-04-05): Appeal: Please check amount of prepaid interest included in your finance charge calculation.  Loan disbursed on XX/XX/XXXX and three days per diem was collected through XX/XX/XXXX.
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158482910   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482915   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482915   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482915   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided) Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482915   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482915   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482915   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Michigan Prepayment Penalty Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482915   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158482915   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158482929   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Missing Document: Flood Insurance Policy not provided       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158482929   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158482929   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158482929   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158482929   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Flood Insurance Error: Insurance premium was not provided.       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158482929   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158482929   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158482937   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158482937   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482941   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482941   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482942   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158482942   XXXX XXXX XX/XX/XXXX Credit Title Lien Title Missing evidence of lien position on Other Financing. Lien Position: 2     Reviewer Comment (2024-04-19): Exception remains, final 1003 and approval list subordinate financing but missing Note and terms of subordinate.


Buyer Comment (2024-04-17): Concerning lien position for subject loan please see Title Policy pages 743-751 D0537 insuring us in 1st Position. Title company would handle any subordination however title commitment shows no other liens. Credit Report page 629-631 D0066 shows XXXX opened XX/XX/XXXX reporting as revolving and included in borrower's DTI. Your file also included a QCD page 55 D0003 from XXXX to XXXX and XXXX. In trailing docs page 2805 there is a Lexis Nexis verifing release of  multiple loans from XXXX dated XX/XX/XXXX and XX/XX/XXXX.


Reviewer Comment (2024-04-08): Per the 1003 in the file Details of Transaction includes Subordinate Financing i/a/o $XXXX.


Buyer Comment (2024-04-05): 4/5/2024: Appeal. Please identify the other financing referenced on the Exception Notes. LL


Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158482942   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158482942   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158482946   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482946   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496309   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496313   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158482967   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.   Reviewer Comment (2024-04-04): Exception remains, missing initial lenders 1003. Alt application date captured as XX/XX/XXXX


Buyer Comment (2024-04-04): Please see page D0591 for application date of XX/XX/XXXX.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482967   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. Captured as per source document   Reviewer Comment (2024-04-08): Exception remians, The final rule provides that delivery of notice must take place within a “reasonable time” before the completion of the transaction. What constitutes “reasonable” notice may vary according to the individual circumstances of a transaction. The preamble to the final rule states that the agencies generally continue to regard ten days as a “reasonable” time interval. However, in all cases an institution should bear in mind that a borrower should receive notice timely enough to ensure that borrower had opportunity to obtain flood insurance.


Buyer Comment (2024-04-05): 04.05.24 Appeal attached Notice of Special Flood dated XX/XX/XXXX and XX/XX/XXXX kindly advise.gs.


Reviewer Comment (2024-04-04): Exception remains, disclosure stamped XX/XX/XXXX is not the Special Flood Hazards disclosure associated with the review.


Buyer Comment (2024-04-03): 4.3.24 Appeal attached Flood Zone Timing Notification Special Hazard in AMC p129of2003 -D 0400 original disclosures mailed to borrower XX/XX/XXXX-XX/XX/XXXX-and signed XX/XX/XXXX kindly review rescind.gs.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482968   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482968   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158482969   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496315   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496320   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496320   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496320   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Louisiana Prepayment Penalty Louisiana Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% (in Years 1-5).  Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%,   which exceeds the max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496320   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496324   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496324   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.     Reviewer Comment (2024-04-08): Exception remains, missing list of the nearest available housing counseling agencies approved by the United States Department of Housing and Urban Development.


Buyer Comment (2024-04-04): See 3rd paragraph on D0803. XXXX provided a number and link to HUD's list of Michigan counselors.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496324   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483003   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided) Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483003   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483003   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483003   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Michigan Prepayment Penalty Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496328   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496331   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Oregon Late Charge Grace Period Testing Oregon Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496331   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Oregon Late Charge Percent Testing Oregon Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496331   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Oregon Prepayment Penalty Max Prepay Oregon Prepayment Penalty: Loan agreement or Note does not clearly state the maximum prepayment penalty applicable to each year of the loan.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496331   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483013   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483013   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483013   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483013   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483013   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Flood Insurance Error: Policy number is not provided.       Reviewer Comment (2024-04-19): Exception remains, flood policy does not contain policy number.


Buyer Comment (2024-04-17): Flood Policy Number does show pending page 928 D0564 subject closed XX/XX/XXXX;  however please review HUD-1 page 265 D0016 line 904 premium of $XXX paid out of closing to XXXX same as policy and  the flood insurance is also set up for monthly escrow
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483031   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483031   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Flood Certificate Error: Certificate Number was not provided.       Reviewer Comment (2024-04-08): Exception remains, missing flood determination certificate number from flood cert.


Buyer Comment (2024-04-04): Flood Hazard Determination in file page D0824 showing property in flood zone X  along with map number and date.  Please confirm a certificate number is required as page two of the flood determination does not show a certificate number requirement.  Thanks.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483034   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483034   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483038   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483038   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496338   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496338   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483053   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496347   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496347   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496347   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496348   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496348   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Wisconsin Late Charge Amount Testing First Lien Wisconsin Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496348   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Wisconsin Late Charge Grace Period Testing > $25,000 Wisconsin Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496348   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Wisconsin Prepayment Penalty ARM Test Wisconsin Prepayment Penalty:  Adjustable rate loan containing prepayment penalty did not provide disclosure stating that there are also loans available without prepayment penalties.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483081   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483081   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Missouri Late Charge Grace Period Testing Missouri Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483081   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Missouri Prepayment Penalty Missouri Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483083   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483083   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496352   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496352   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Illinois Late Charge Percent Testing Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496352   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496353   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Massachusetts Late Charge Grace Period Testing Massachusetts Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496353   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Massachusetts Late Charge Percent Testing Massachusetts Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 3%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496353   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483097   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483097   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483102   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483102   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.     Reviewer Comment (2024-04-09): No action. Comment reflects not able to locate.


Buyer Comment (2024-04-08): 4/8/2024 Unable to locate FACT Credit Score Disclosure in Acuity or EIV. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483102   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483102   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect Federal HOEPA Ability to Repay Reliable Documentation Truth in Lending Act (HOEPA): Borrower’s ability to repay not verified with reliable documentation.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (Notice to Assignee) Truth in Lending Act (HOEPA): Required Statement was not provided to purchaser or assignee for loan that was sold or assigned. (Note: This notice only applies when selling or assigning a HOEPA loan and may not be found in the file for loans that have not been previously sold)               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Legal / Regulatory / Compliance Anti-Predatory Violation Federal Defect (Fed High Cost Disclosure) Federal High-Cost Mortgage Loan (HOEPA Disclosure Not Provided) Truth in Lending Act (HOEPA):  HOEPA disclosure was not provided to the Borrower               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Federal Defect (Fed High Cost) Federal High-Cost Mortgage Loan (Points and Fees) Truth in Lending Act (HOEPA): Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of X.XX% of the Federal Total Loan Amount and $XXXX XXXX. Points and Fees of $XXXX on a Federal Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Compliance Disclosed Note P&I payment does not equal calculated P&I payment Disclosed Note P&I payment does not equal calculated P&I payment.  Note P&I of $XXXX does not match calculated P&I of $XXXX. Calculated P&I was used for the APR calculation and compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Louisiana Late Charge Percent Testing Louisiana Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Louisiana Prepayment Penalty Louisiana Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% (in Years 1-5).  Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%,   which exceeds the max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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     Reviewer Comment (2024-04-09): Unable to conclusively determine date of consummation. Missing Security Instrument Notary Date. Exception remains.


Buyer Comment (2024-04-09): Please see final TIL dated XX/XX/XXXX by the borrower which verifies exact date of closing
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496360   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes C
XXXX   3158483112   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483112   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483112   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-08): No action. Unable to locate per response comments.


Buyer Comment (2024-04-05): 4/5/2024 Unable to locate the initial ARM Disclosure after reviewing Acuity and EIV. JF
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496364   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496364   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-05): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-04): 4/4/2024 Appeal: Please find attached verification for the application date of 0XX/XX/XXXX. CK
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496364   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.     Reviewer Comment (2024-04-05): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-04): 4/04/2024 Appeal: Please see the uploaded validation (exception id XXXX)  which reflects the application date of 0XX/XX/XXXX. D0229 – ABA dated 0XX/XX/XXXX. CK
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496364   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-05): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-04): 04/04/2024 Appeal: Please see the uploaded document (exception id XXXX)  with confirms the application date of XX/XX/XXXX which is the date the ARM Disclosure was sent to the borrower. CK
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496364   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-05): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-04): 04/04/2024 Appeal: Please see the uploaded document (exception id XXXX)  with confirms the application date of XX/XX/XXXX which is the date the CHARM Booklet was sent to the borrower. CK
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483120   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided) Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483120   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483120   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483120   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Michigan Prepayment Penalty Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483120   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483120   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483135   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483135   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.     Reviewer Comment (2024-04-08): No action. Comments reflect unable to locate.


Buyer Comment (2024-04-08): 4/8/2024 Unable to locate FACTA Credit Score Disclosure in EIV or Acuity. JF
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483135   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483139   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.     Reviewer Comment (2024-04-08): No action. Comment advises unable to locate.


Buyer Comment (2024-04-08): 4/8/2024 Unable to locate FACTA Credit Score Disclosure.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483139   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Missouri Late Charge Grace Period Testing Missouri Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483139   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Missouri Prepayment Penalty Missouri Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483139   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496374   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483146   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483146   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483146   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483146   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496377   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496377   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exempt from federal and state high cost testing.  Exception regraded to EV2-B.
        2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158483158   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483158   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496380   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496380   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496380   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483175   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158483175   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483175   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483175   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483180   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483180   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483180   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Maryland Interest and Usury Prepayment Penalty Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483180   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Maryland Late Charge Grace Period Testing Maryland Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483180   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Maryland Late Charge Percent and Amount Testing Maryland Late Charge: Note late charge of X.XX%/$XXXX exceeds state maximum of 5% or $2, whichever is greater.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483180   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483181   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483181   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Compliance Disclosed Note P&I payment does not equal calculated P&I payment Disclosed Note P&I payment does not equal calculated P&I payment.  Note P&I of $XXXX does not match calculated P&I of $XXXX. Calculated P&I was used for the APR calculation and compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483181   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483181   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483181   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483183   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483184   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483184   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496388   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496388   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided) Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496388   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496388   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496388   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Michigan Prepayment Penalty Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496388   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496388   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496388   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483193   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483193   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496392   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496392   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496392   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483203   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483203   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483203   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496396   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496396   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496396   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483209   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483209   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483210   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483210   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496399   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496399   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496401   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496401   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Maryland Interest and Usury Prepayment Penalty Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496401   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Maryland Late Charge Grace Period Testing Maryland Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496401   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Maryland Late Charge Percent and Amount Testing Maryland Late Charge: Note late charge of X.XX%/$XXXX exceeds state maximum of 5% or $2, whichever is greater.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496402   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496402   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Virginia Late Charge Percent Testing Virginia Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496404   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496404   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496404   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Illinois Late Charge Percent Testing Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496404   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496406   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.   Reviewer Comment (2024-04-11): Exception remains, While notary fees are excluded from finance charges and APR calculations, only the notary fee portion is excludable but signing fees and mobile services are not and these would be included as finance charges. Commentary to Regulation Z 1026.4(e)(1) provides:
1. Notary fees. In order for a notary fee to be excluded under §1026.4(e)(1), all of the following conditions must be met:
2. The document to be notarized is one used to perfect, release, or continue a security interest.
3. The document is required by law to be notarized.
iii. A notary is considered a public official under applicable law.
1. The amount of the fee is set or authorized by law.
If evidence can be provided that any portion of the Signing Fee was for notarizing documents as detailed above, that portion can be excluded from finance charges.


Buyer Comment (2024-04-09): Appeal:  The $150 difference in finance charges appears to be the vendor including the $150 signing fee, but it appears a signing fee listed in the 1100 series of the HUD-1 is not considered a finance charge.
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496406   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483226   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483226   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483230   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483230   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.   Reviewer Comment (2024-04-19): Exception remains, Missing itemization of amount financed to determine what fees were disclosed on the TIL as prepaid finance charges.


Buyer Comment (2024-04-18): Unable to account for variance in LAS Report using the same PPFCs. XXXX recalculation did not result in a variance of the PPFCs. The total disclosed pre-paids was $XXXX (Loan Amount $XXXX - TIL Amount Financed $XXXX). The PPFC's totaling $XXXX includes: Loan Origination Fee $2,500 + Tax Service Fee $84 + Processing Fee $500 + UW Fee $300 + Flood Cert $5 + Broker Fee $495 + Processing Fee $500 + Courier/Messenger Fee $20 – Prepaid Interest $128.05 + Settlement Fee $450 + Title Courier $50 + Wire Fee $35 + Loan Tie-in Fee $100 + Sub-Escrow Fee $150 + Check Processing Fee $40 + Recording Fee $69 + Title Courier Fee $10 + Wire $10.
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483230   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483236   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483237   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Missouri Late Charge Grace Period Testing Missouri Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483237   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Missouri Prepayment Penalty Missouri Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483237   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483237   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496410   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496410   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to verify finance charge under disclosure due to missing TIL Itemization.   Reviewer Comment (2024-04-05): While notary fees are excluded from finance charges and APR calculations, only the notary fee portion is excludable but signing fees and mobile services are not and these would be included as finance charges. Commentary to Regulation Z 1026.4(e)(1) provides:
1. Notary fees. In order for a notary fee to be excluded under §1026.4(e)(1), all of the following conditions must be met:
2. The document to be notarized is one used to perfect, release, or continue a security interest.
3. The document is required by law to be notarized.iii. A notary is considered a public official under applicable law.
1. The amount of the fee is set or authorized by law.
If the fee disclosed represents a notary and signing fee lumped together, the total would be considered a finance charge unless it can be demonstrated which portion was allocated for which service. If documentation can be provided identifying which portion of charge was for notarizing documents, we can exclude this portion from finance charges.


Buyer Comment (2024-04-04): 4/4/24-Appeal : Doc Signing ($425) aka Notary Fee is not a PPFC. Please recalculate. TC
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483246   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483246   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496413   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496413   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496413   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Illinois Late Charge Percent Testing Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496413   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483267   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483267   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Pennsylvania First Lien Late Charge Grace Period Testing Pennsylvania Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483267   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483272   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Wisconsin Late Charge Amount Testing First Lien Wisconsin Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483272   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Wisconsin Late Charge Grace Period Testing > $25,000 Wisconsin Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483272   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Wisconsin Prepayment Penalty Wisconsin Prepayment Penalty: Maximum prepay  allowed per state is 60 days interest calculated on 80% of the original loan amount ($XXXX).  Loan contracts for maximum calculated prepay of $XXXX, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483272   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483283   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483283   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Maryland Interest and Usury Prepayment Penalty Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483283   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Maryland Late Charge Grace Period Testing Maryland Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483283   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Maryland Late Charge Percent and Amount Testing Maryland Late Charge: Note late charge of X.XX%/$XXXX exceeds state maximum of 5% or $2, whichever is greater.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483283   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496427   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496427   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496427   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483287   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158483287   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483309   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483309   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483309   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Delaware Late Charge Percent Testing Delaware Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483309   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483309   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483309   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483319   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483319   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483319   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483319   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483320   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA 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.     Reviewer Comment (2024-04-04): Exception remains. Application date XX/XX/XXXX. ABA located in file dated XX/XX/XXXX.


Buyer Comment (2024-04-03): Appeal - ABA signed and dated XX/XX/XXXX.  CG
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483320   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Mississippi Late Charge Percent and Amount Testing > $100,000 Mississippi Late Charge: Note late charge of X.XX%/$XXXX exceeds state maximum of 4% or $5, whichever is greater.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483320   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Mississippi Prepayment Penalty Mississippi Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% [in Years 1-5]. Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%, X.XX%, X.XX%, which exceeds the max allowable. Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483320   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483320   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486308   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486308   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486308   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486308   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Illinois Late Charge Percent Testing Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486308   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486308   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158486308   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486318   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486318   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486318   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486318   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486318   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. Document provided at the time of closing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496441   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496441   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496441   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496441   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496441   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483348   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483348   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483348   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483348   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483348   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483350   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483350   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483350   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483350   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483350   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483350   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158483352   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483352   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Missouri Late Charge Grace Period Testing Missouri Late Charge: Note grace period of 10 days is less than the state minimum of 15 days.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Illinois Late Charge Percent Testing Illinois Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.     Reviewer Comment (2024-04-18): As noted in the comment Transaction Date XX/XX/XXXX but the transaction disbursed XX/XX/XXXX (prior to the 3 business day rescission period). Eligible to disburse XX/XX/XXXX. Exception remains.


Buyer Comment (2024-04-17): Please see Security Instrument Page 3 D0002 showing owner XXXX as Trustee under Trust Number XXXX which was executed i day prior to close XX/XX/XXXX which by law is allowed. Please see Trustee's Deed of Trust page 40 D0005 as well as Declaration of Certification of Trust signed by borrower page 568 D0348. Title Policy verifies the same page 878-880 D0375.. RTC pages 180-181 D0199 verification borrower received 3 working days to cancel copy of calendar attached as well as TIL page 92 D0198.


Reviewer Comment (2024-04-10): Exception remains, Notary date is 0XX/XX/XXXX.


Buyer Comment (2024-04-09): 4/9/2024: Appeal. The final TIL in Clarity doc # 0198/D#0642 was executed on XX/XX/XXXX not XX/XX/XXXX. Therefore, the disbursement date of XX/XX/XXXX was well within the 3 days after consummation. LL
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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 (2024-04-18): As noted in the comment Transaction Date XX/XX/XXXX but the transaction disbursed XX/XX/XXXX (prior to the 3 business day rescission period). Eligible to disburse XX/XX/XXXX. Exception remains.


Buyer Comment (2024-04-17): Please see Security Instrument Page 3 D0002 showing owner XXXX as Trustee under Trust Number XXXX which was executed i day prior to close XX/XX/XXXX which by law is allowed. Please see Trustee's Deed of Trust page 40 D0005 as well as Declaration of Certification of Trust signed by borrower page 568 D0348. Title Policy verifies the same page 878-880 D0375.. RTC pages 180-181 D0199 verification borrower received 3 working days to cancel copy of calendar attached as well as TIL page 92 D0198.


Reviewer Comment (2024-04-10): Exception remains, Notary date is 0XX/XX/XXXX.


Buyer Comment (2024-04-09): 4/9/2024: Appeal. The final TIL in Clarity doc # 0198/D#0642 was executed on XX/XX/XXXX not XX/XX/XXXX. The ROR doc #0199 also reflected full execution on XX/XX/XXXX. Therefore, the disbursement date of XX/XX/XXXX was well within the 3 days after consummation. LL
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158483369   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483380   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483380   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483380   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483380   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Alabama Late Charge Percent and Amount Testing Alabama Late Charge: Note late charge of X.XX%/$29.00 exceeds state maximum of 5% or $10, whichever is greater.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     Yes B
XXXX   3158483380   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Alabama Prepayment Penalty Alabama Prepayment Penalty: A prepayment penalty is not permitted under the Consumer Credit Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483380   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Disclosed payment on Note does not correspond with the loan amount, loan term, and interest rate on the loan.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496459   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496459   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496459   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496459   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Louisiana Late Charge Percent Testing Louisiana Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496459   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Louisiana Prepayment Penalty Louisiana Prepayment Penalty: Maximum penalty allowed per state is 5%, 4%, 3%, 2%, 1% (in Years 1-5).  Loan contracts for prepay percentages of X.XX%, X.XX%, X.XX%, X.XX%, X.XX%, which exceeds the max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496459   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496459   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496459   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. Captured as per data source             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Provision) New York High-Cost Loan (Ability to Repay not Verified) New York High-Cost Loan:  Borrower’s ability to repay not verified with reliable documentation.               3 XX/XX/XXXX XX Primary Refinance - Rate/Term No obvious cure C C C C C     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided) New York High-Cost Loan: Borrower not provided with Aggregate Monthly Payment Disclosure statement.               3 XX/XX/XXXX XX Primary Refinance - Rate/Term No obvious cure C C C C C     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided) New York High-Cost Loan: Borrower not provided with Consumer Caution and Home Ownership Counseling Notice.               3 XX/XX/XXXX XX Primary Refinance - Rate/Term No obvious cure C C C C C     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided) New York High-Cost Loan: Counseling Disclosure not provided to borrower.               3 XX/XX/XXXX XX Primary Refinance - Rate/Term No obvious cure C C C C C     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold) New York High-Cost Loan: Lender financed points and fees in excess of 3% of the total loan amount.               3 XX/XX/XXXX XX Primary Refinance - Rate/Term Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage) New York High-Cost Loan: Mortgage does not contain legend advising loan is high-cost.               3 XX/XX/XXXX XX Primary Refinance - Rate/Term Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application) New York High-Cost Loan: Mandatory "Shop Around" Notice not included on loan application to applicant.               3 XX/XX/XXXX XX Primary Refinance - Rate/Term No obvious cure C C C C C     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost) New York High-Cost Loan (Points and Fees) New York Anti-Predatory Lending Statute: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of X.XX% of the Total Loan Amount and $XXXX XXXX. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.               3 XX/XX/XXXX XX Primary Refinance - Rate/Term Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     Yes C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No C
XXXX   3158483396   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data (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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No C
XXXX   3158483418   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158483418   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483418   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483418   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483418   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483418   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483418   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483419   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158483419   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483419   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483419   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483419   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483419   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483419   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status Unable to determine if loan file contains CHARM Booklet due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483427   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Investment Purchase   C C C C C     No B
XXXX   3158483427   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158483427   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158483427   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158483431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483441   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483441   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483456   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-19): Unable to determine specific property type (i.e. attached/detached) from images provided. Exception remains.


Buyer Comment (2024-04-19): Subject is an XXXX Streamline Refinance which could only be done on SFR Please see your Property report page 1 D00938 shows SFR Please see Homeowners policy page 762 D0570 as well as XXXX Connection page 154 D0029., I am also attaching rate lock which shows SFR


Reviewer Comment (2024-04-17): Exception remains, Unable to determine specific property type at origination.


Buyer Comment (2024-04-16): 04/10/2024 - Appeal. Please see Final 1003 page 62/2816 D 0571 which reflects the Type of Property as SFR.  AS
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483456   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure is TIL disclosing MI dropping off after 38 months and calculated running through term of loan.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483456   XXXX XXXX XX/XX/XXXX Compliance Property - Appraisal General Appraisal Requirements LTV Test Due to lack of appraised value, compliance tests requiring an LTV were run off an assumed value of a contract sales price or original loan amount, whichever applies.                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483456   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance TILA Prepayment Penalty Discrepancy Final TIL / CD indicates loan has PPP, however file does not contain prepayment penalty addendum. Missing prepay data may result in invalid high cost, FNMA, and/or QM points and fees findings.     Reviewer Comment (2024-04-17): Exception remains, Exception is for variance of note not having a prepayment penalty and TIL stating may have a prepayment.


Buyer Comment (2024-04-16): 04-16-2024  Appeal.  Subject loan is an XXXX loan and cannot have a prepayment penalty.  Please note the TIL states the loan "may" have a PPP, but does not specifically state that is does. The Note itself specifies there is no PPP in paragraph 5. MC
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483456   XXXX XXXX XX/XX/XXXX Credit Disclosure Missing Document Disclosure XXXX Informed  Consumer Choice Disclosure is missing. Disclosure: XXXX - Informed Consumer Choice Disclosure (Government Documents)     Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No B
XXXX   3158483456   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483456   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496487   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-09): Exception remains, flood determination referencing is post origination.


Buyer Comment (2024-04-09): Please see flood cert page D0458 showing subject in flood zone C.


Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No A
XXXX   3158483507   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483507   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483507   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483507   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-19): Unable to determine specific property type at time of Origination  (i.e. to include attached/detached for Single Family Dwellings) with documentation provided. Exception remains.


Buyer Comment (2024-04-19): We have already furnished ValueSure Property Valuation Report giving value of $XXXX and SFR. Please see Approval page 33 D0-528 which shows SFR and value used $XXXX. Also please look at Homeowners Policy page 557 D0013 which also shows 1 dwelling. Thank You


Reviewer Comment (2024-04-17): Unable to determine if attached or detached. Exception remains.


Buyer Comment (2024-04-17): Please see uploaded doc showing property type.


Buyer Comment (2024-04-17): Appeal. Please see uploaded doc.  Found ValueSure Property Valuation Report dated prior to closing showing property type as SFR.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483519   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158483519   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.     Reviewer Comment (2024-04-19): EXCEPTION HISTORY - Exception Detail was updated on XX/XX/XXXX PRIOR Exception Detail: Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158483519   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158483519   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-15): Exception remains, HUD provided is estimated.


Buyer Comment (2024-04-11): 4-11-24 APPEAL, Providing a copy of the signed HUD statement.  See also page 96, DOC ID 0065 IN Acuity.  /dp
        3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   D D D D D     No D
XXXX   3158496496   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496496   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496496   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496496   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New York Prepayment Penalty New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496496   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496496   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496496   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Itemization did not disclose $310 of the Title pick up Fee as prepaid finance charges.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483562   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483562   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483562   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483562   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483562   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483563   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483563   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483563   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA 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.     Reviewer Comment (2024-04-09): Exception remains, initial lenders 1003 in loan file states XX/XX/XXXX.


Buyer Comment (2024-04-09): 04/09/2024 Appeal: Please the DOC IDs D0132 and D0133 which state the Application Date is actually on XX/XX/XXXX. D0271 validates the borrower was sent the ARM Disclosure, the CHARM Booklet, and the ABA (DOC D0275) on XX/XX/XXXX which is within three days of the application. CK
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483563   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-09): Exception remains, initial lenders 1003 in loan file states XX/XX/XXXX.


Buyer Comment (2024-04-09): 04/09/2024 Appeal: Please the DOC IDs D0132 and D0133 which state the Application Date is actually on XX/XX/XXXX. D0271 validates the borrower was sent the ARM Disclosure, the CHARM Booklet, and the ABA (DOC D0275) on XX/XX/XXXX which is within three days of the application. CK
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483563   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.     Reviewer Comment (2024-04-09): Exception remains, initial lenders 1003 in loan file states XX/XX/XXXX.


Buyer Comment (2024-04-09): 04/09/2024 Appeal: Please the DOC IDs D0132 and D0133 which states the Application Date is actually on XX/XX/XXXX. D0271 validates the borrower was sent the ARM Disclosure, the CHARM Booklet, and the ABA (DOC D0275) on XX/XX/XXXX which is within three days of the application. CK
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496508   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483566   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483572   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483572   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483572   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect California Prepayment Penalty California Prepayment Penalty: Maximum prepay  allowed is 6 months interest calculated on 80% of the original balance ($XXXX).  Loan contracts for maximum calculated prepay of $XXXX, which exceeds max allowable. Prepay may be impermissible depending on the lender's license type.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483572   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483572   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483572   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158483587   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No B
XXXX   3158483587   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483587   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483587   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483587   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483588   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Flood Insurance Error: Policy number is not provided.                 2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158483588   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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.               3 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496511   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483603   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483607   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158483612   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483612   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483623   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.               2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483623   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483623   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483632   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496518   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496518   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496518   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496518   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL Itemization Did not disclose the settlement charge of $570 as a prepaid finance charge..             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496519   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496519   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXXused as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496519   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496521   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158496521   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496521   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496522   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496522   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Connecticut Prepayment Penalty Test Connecticut Prepayment Penalty: A prepayment penalty is not permissible under the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.     Reviewer Comment (2024-04-16): The exemption from the prepayment penalty restriction established in the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act is not a blanket exemption for all mortgage brokers. The mortgage broker or mortgage lender must meet one of the exemptions from licensure established in Section 36a-487 of the Act.  While XXXX meets exemption under 36a-487(a)(1), it is not clear if the lender in the request meet any of the exemptions listed in this section. Please provide information about how each of the lenders meets ones of the exemptions listed in Section 36a-487.Exception remains.


Buyer Comment (2024-04-10): Cited prohibition is applicable to a mortgage broker. Prepayment penalty is payable to XXXX Mortgage which is the lender per Sec. 36a-485. (Formerly Sec. 36-440). Definitions. (19).
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496522   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496522   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496524   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Analysis Insurance The Flood Insurance Policy effective date is after the Note Date. Flood Insurance Policy Effective Date XX/XX/XXXX, Note Date XX/XX/XXXX     Reviewer Comment (2024-04-12): Exception remains flood policy effective date is XX/XX/XXXX


Buyer Comment (2024-04-11): Please see application for flood.


Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158496524   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496524   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496524   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.   Reviewer Comment (2024-04-12): Exception remains, missing notice of special flood hazard from loan file.


Buyer Comment (2024-04-12): Please see Sales Contract #246 buyer was aware of needing flood insurance at time of contract
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483666   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483674   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158483674   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483674   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-16): Exception remains, missing application date.


Buyer Comment (2024-04-16): 4/15/2024 Please see disclosure pkg uploaded for exception #30268599. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483674   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-16): Exception remains, missing application date.


Buyer Comment (2024-04-16): 4/15/2024 Please see disclosure pkg uploaded with #30268599. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158483674   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483674   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. Exception remains, Missing notice of notice of special flood hazard from XX/XX/XXXX.   Reviewer Comment (2024-04-19): Exception remains, Missing Notice of special flood hazard from XX/XX/XXXX.


Buyer Comment (2024-04-17): 4/17/2024 Please re-review earliest food cert which is dated XX/XX/XXXX and signed by the customer which would constitute notice of a flood hazard.JF


Reviewer Comment (2024-04-16): Exception remains, notice of special flood hazards dated XX/XX/XXXX not in loan file.


Buyer Comment (2024-04-15): 4/15/2024 Please see flood cert dated XX/XX/XXXX which is signed by the customer.


Buyer Comment (2024-04-15): 4/15/2024 Please see the  flood cert dated XX/XX/XXXX and signed by the borrower. The borrower was refinancing a condo and flood insurance was included with the master policy.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496534   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496534   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496534   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496534   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483676   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-10): Exception remains, Flood determination referenced does not list any information.


Buyer Comment (2024-04-09): 4/9/2024: Please reference page 726 doc ID 0292 for the Lender Flood Cert. LM


Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158483676   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483676   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483676   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483676   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483680   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483680   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483680   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496537   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496537   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-15): Exception remains, unable to determine property type at origination SFR Attached or Detached.


Buyer Comment (2024-04-12): Please look at Home Value Explorer page 2370 D1812 which clearly states subject was SFR and I am enclosing a legible copy of hazard insurance which also verifies SFR


Reviewer Comment (2024-04-10): Exception remains, unable to determine property type at origination SFR Attached or Detached.


Buyer Comment (2024-04-10): Shows subject is a SFR.


Buyer Comment (2024-04-10): Please see attached for verification subject was a SFR.  Thanks.


Reviewer Comment (2024-04-10): Exception remains, unable to determine property type at origination.


Buyer Comment (2024-04-09): Please see page D0650 for confirmation of property type: Single Family
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496537   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely) Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower at the time of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496537   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower at the time of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496537   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483691   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483691   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely) Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower at the time of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483691   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower at the time of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483691   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List Timing) Michigan Consumer Mortgage Protection Act:  List of HUD-approved credit counseling agencies not provided to borrower at the time of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483698   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483698   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483698   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483698   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496541   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496541   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496541   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483702   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No D
XXXX   3158483702   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No D
XXXX   3158483702   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  No Document Used For Fee Testing Material Missing Final HUD-1.  No document containing fees provided.  Any applicable Federal, State or Local compliance testing is unreliable.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   D D D D D     No D
XXXX   3158483702   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application No Fees No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation.  A lookback was performed to determine this application date. Due to missing HUD-1 or Closing Disclosure, no fees were used in testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No D
XXXX   3158483702   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-04): Exception remains.  D0722 and D0557 does not include if Single Family Detached or Single Family Attached.  D0762 is not from time of Origination.


Buyer Comment (2024-04-04): 04/04/2024 - Appeal: Please see DOC D0722 – Loan approval which states the property type is a SFR, D0557 – Market Intelligence Report - confirms SFR, and  D0762 which validates the subject property is a SFR Attached. CK
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No D
XXXX   3158483702   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No D
XXXX   3158483702   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No D
XXXX   3158483733   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483733   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483765   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483765   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.     Reviewer Comment (2024-04-09): Exception remains, missing Notice of special flood hazard from loan file.


Buyer Comment (2024-04-09): 04/09/2024 Appeal: Please see DOC D0209, disclosure notices, which contains the flood insurance notification. The flood notification states the borrower will be asked to acknowledge their receipt of this information. D0242 is the borrower’s acknowledgment. CK
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496561   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496561   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIl Itemization did no disclosure settlement closing escrow fee of $176 as prepaid finance charge.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483776   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483776   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483776   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483777   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158483777   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483777   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496562   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496562   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496562   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483784   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483784   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483784   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483806   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483806   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483808   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483808   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New York Prepayment Penalty New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.     Reviewer Comment (2024-04-12): Response to request. Citations listed.  N.Y. Comp. Code. R. & Regs. tit. 3, §§ 82.1(a), 82.7,N.Y. Gen. Oblig. Law § 5-501(3)(b).


Buyer Comment (2024-04-11): Appeal:  Please provide statute
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483808   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483808   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483811   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483811   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect South Carolina CHL Complaint Agency Disclosure Timing Test South Carolina Home Loan: Borrower not provided with a document, at time of application, specifying the agency designated to receive complaints or inquiries about the origination and making of the loan.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483811   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483811   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL itemization did not disclose an Attorney fee of $350, Flood cert fee of $12 and Assignment recording fee of $6 as prepaid finance charge.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483826   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483826   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483826   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483859   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No B
XXXX   3158483859   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New York Prepayment Penalty New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483859   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIl itemization did not disclose Assignment mortgage$70, Title closer pick-up fee$175.00 and Title courier/Messenger fee $60 as prepaid finance charge.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483859   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.     Reviewer Comment (2024-04-10): Exception remains, Disbursement date from HUD is XX/XX/XXXX.


Buyer Comment (2024-04-09): Please see page D0007 showing actual disbursement date of XX/XX/XXXX.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158483859   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483859   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483868   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483868   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483868   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty) Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 60 days interest on the unpaid principal balance.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483868   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 2% of the unpaid principal balance of the loan. Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483868   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483868   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483868   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158483868   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496589   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496589   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496589   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496589   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483878   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158483878   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483878   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483878   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483878   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483878   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483883   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483883   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483883   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483883   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496597   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496597   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496597   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496600   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158496600   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496600   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496600   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496600   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496600   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496600   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.     Reviewer Comment (2024-04-15): Exception remains, TIL referenced is not final.


Buyer Comment (2024-04-11): 4/11/2024 Appeal. Please reference page number 108, doc code 0477, for the final TIL with signature date of XX/XX/XXXX. RC
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483894   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483894   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483894   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158483894   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Massachusetts Prepayment Penalty Massachusetts Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 3 months interest  ($XXXX).               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158483912   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496608   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158496608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496614   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing Unable to test Affiliated Business Disclosure due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496614   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Borrower Bill of Rights Disclosure Not Provided Timely) Michigan Consumer Mortgage Protection Act:  Borrower Bill of Rights disclosure not provided to borrower at the time of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496614   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Caution and Home Ownership Counseling Notice Not Provided Timely Michigan Consumer Mortgage Protection Act:  Consumer Caution and Home Ownership Counseling Notice not provided to borrower at the time of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496614   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Michigan Consumer Mortgage Protection Act (Counseling Agencies List) Unable to test counseling agencies list due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496614   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Michigan Prepayment Penalty Michigan Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496614   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL Itemization did not disclose Settlement/Closing/Escrow Fee of $175 and Title Courier/Messenger Fee of $20.00 as prepaid finance charges.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496614   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496615   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496615   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect District of Columbia Prepayment Penalty District of Columbia Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX). Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158483941   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Missing Document: Flood Insurance Policy not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158483941   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483941   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483941   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483941   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483941   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483941   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158483941   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158483944   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483944   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483944   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483944   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483944   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158483944   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483944   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158483945   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483945   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496616   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496616   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing a lower index than available within look back. Lowest index within look back is X.XX%.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496616   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496616   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New York Prepayment Penalty New York Prepayment Penalty: A prepayment penalty is not permissible on an adjustable rate loan less than $XXXX and an introductory period less than 5 years.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496616   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496616   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158496620   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496620   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496620   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL itemization did disclose an Prepaid interest of $221.76  as prepaid finance charge.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496620   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483982   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158483986   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Investment Refinance - Rate/Term   C C C C C     No B
XXXX   3158483986   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data (other than HUD-1 or Note) Disparity in Occupancy - Not High Cost and Not Higher Priced The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Investment).               2 XX/XX/XXXX XX Investment Refinance - Rate/Term   B B B B B     No B
XXXX   3158496621   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496621   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.
Finance Charge Variance of $3303.58 is due to difference in lender's accepted payment stream as per final til and actual calculated payment stream.
            2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483994   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158483994   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483994   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483994   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158483994   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158483994   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483994   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158483994   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-16): Exception remains, missing ARM disclosure dated within 3 days of application from loan file.


Buyer Comment (2024-04-15): 4-12-24 APPEAL, Providing evidence the ARM disclosure was provided to the borrower at the time of Lenders application.  /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496622   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-15): 4-15-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496622   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.     Reviewer Comment (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-15): 4-15-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  See Trailing documents uploaded to exception ID 30269516  /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496622   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496622   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-15): 4-15-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  See Trailing documents uploaded to exception ID 30269516  /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496622   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-15): 4-15-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  See Trailing documents uploaded to exception ID 30269516  /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496622   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158496622   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing a lower index than available within look back. lowest index within look back is X.XX%.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484010   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No A
XXXX   3158486368   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158484032   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484032   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484032   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing an index lower than available within look back. Lowest index within look back is X.XX%.   Reviewer Comment (2024-04-09): Rounding per the Note .001%. Exception remains.
Commitment letter indicates the Index is X.XX% The Index per the lookback is X.XX%


Buyer Comment (2024-04-09): 4/9/24- Please review for rounding. TC
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496632   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496632   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Compliant Test TIL variable rate disclosure: ARM loan program disclosure does not match terms of loan.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496632   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496632   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496632   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496636   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496636   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-23): Exception remains, unable to determine specfic property type at origination. Documents reference a SFR. Unable to determine if the SFR is attached, Detached or a PUD.


Buyer Comment (2024-04-23): sorry Mortgage history for area


Buyer Comment (2024-04-23): Please see page 510-511 D0078 Home Value Explorer that states address is a residential single family residence- I am also attaching the dwelling insurance as I can see you do not the full policy- Also enclosing mortgage history for area which you don't have all of which indicate the subject is 1 building residential


Reviewer Comment (2024-04-10): Exception remains. Unable to determine property type at time of origination SFR Attached or SFR Detached.


Buyer Comment (2024-04-10): Appeal - Various documents in the loan file reflect the subject property type as SFR.  Loan application, appraisal and property report reflect as SFR.  CG
        2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496642   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA 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.     Reviewer Comment (2024-04-17): Exception remains, copy of affiliated business disclosure from XX/XX/XXXX is missing from loan file.


Buyer Comment (2024-04-16): 4-16-24 APPEAL, Providing evidence of Lender’s initial disclosure to the borrower.  /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496642   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. IL itemization did not disclose processing fee of $550, Wire transfer fee of $35 and wire fee of $30 as prepaid finance charges. Additionally, Finance charge under disclosure due to Prepaid interest fee amount of $511.83 and over disclosure due to Settlement fee of $360             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496642   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496644   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484091   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484091   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484104   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158484104   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484104   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484104   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496649   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496649   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496649   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496649   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158496654   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496654   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496654   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496654   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Connecticut Prepayment Penalty Test Connecticut Prepayment Penalty: A prepayment penalty is not permissible under the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496654   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496654   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496657   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496657   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496657   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496658   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496658   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496659   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496659   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484136   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484136   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used. Application received date not acceptable.


Buyer Comment (2024-04-12): 04-12-2024  Appeal2.  Please confirm receipt of Lender Letter which specifies the Application Date as XX/XX/XXXX.  This was included in prior appeal docs, but unable to access in Acuity now. Uploading as seperate document now.  MC


Reviewer Comment (2024-04-11): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-10): 04-10-2024  Appeal.  XXXX acknowledges the missing lender 1003; however, the loan file does contain a lender letter specifically stating the application was received on XX/XX/XXXX which should establish an valid application date. MC
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.     Reviewer Comment (2024-04-11): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-10): 04-10-2024  Appeal.  XXXX acknowledges the missing lender 1003; however, the loan file does contain a lender letter specifically stating the application was received on XX/XX/XXXX which should establish an valid application date. The ABA dosclosure is dated XX/XX/XXXX. MC
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-11): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-10): 04-10-2024  Appeal.  XXXX acknowledges the missing lender 1003; however, the loan file does contain a lender letter specifically stating the application was received on XX/XX/XXXX which should establish an valid application date. The ARM dosclosure is dated XX/XX/XXXX. MC
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-11): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-10): 04-10-2024  Appeal.  XXXX acknowledges the missing lender 1003; however, the loan file does contain a lender letter specifically stating the application was received on XX/XX/XXXX which should establish an valid application date. The ARM dosclosure is dated XX/XX/XXXX. MC
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496678   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496678   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496678   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496678   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496678   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484159   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484159   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484159   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484159   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484159   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484159   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484159   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484170   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484170   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484170   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484170   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484173   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Missing Document: Flood Insurance Policy not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158484173   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Flood Insurance Error: Insurance premium was not provided.       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158484173   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Flood Flood Insurance Policy Missing The subject property is in a flood zone, evidence of flood insurance was not provided/obtained. Failure to obtain and disclose required insurance may result in additional federal and/or state compliance violations.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484173   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure within a reasonable time prior to closing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484173   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496682   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496683   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   D D D D D     No D
XXXX   3158496683   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No D
XXXX   3158484181   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No B
XXXX   3158484181   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data (Missing Data) Flood Hazard Zone Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone indicator was not provided. The applicable flood zone related testing cannot be performed.     Reviewer Comment (2024-04-16): Exception remains missing flood determination from origination.


Buyer Comment (2024-04-15): attached hereto also


Buyer Comment (2024-04-15): 4.15.24 Appeal page897of4095 D-0663 Notice of Special Flood dated XX/XX/XXXX signed  XX/XX/XXXX-reasonable time before Note date XX/XX/XXXX refinance kindly rescind.gs
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484181   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484189   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484189   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484189   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484189   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Wisconsin Prepayment Penalty ARM Test Wisconsin Prepayment Penalty:  Adjustable rate loan containing prepayment penalty did not provide disclosure stating that there are also loans available without prepayment penalties.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484189   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484189   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484190   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484190   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484190   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484190   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484190   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484190   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484202   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484202   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-15): Exception remains, missing Arm disclosure from XX/XX/XXXX


Buyer Comment (2024-04-11): 4/11/2024 Appeal. Please reference page number 3756, doc code 0635, for Disclosure Letter dated XX/XX/XXXX showing the ARM Loan Disclosure was provided to the borrower within 3 business days of application. RC
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484207   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158484207   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   D D D D D     No D
XXXX   3158484207   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158484207   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No D
XXXX   3158484207   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date and RTC Signature Date. Unable to determine compliance with rescission timing requirements.     Reviewer Comment (2024-04-16): Exception remains, TIL not dated by borrower.


Buyer Comment (2024-04-12): 4/12/2024: Appeal - Please refer to Closing Instructions (D0022) and ROR (D0184). ROR was provided to the borrower at closing and document is initialed acknowledging receipt. SG
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes D
XXXX   3158484207   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158484207   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158484211   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496697   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158496697   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158484215   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158484215   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exempt from federal, state and local high cost testing.  Exception regraded to EV2-B.
        2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158484215   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158484223   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484223   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Minnesota Residential Mortgage Originator and Servicer Licensing Act (Impermissible Prepayment Penalty) Minnesota Residential Originator and Servicer Licensing Act: Mortgage loan contains an impermissible prepayment penalty exceeding 60 days interest on the unpaid principal balance.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484223   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.   Reviewer Comment (2024-04-16): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-12): 4/12/2024 Please re-review the multi disclosure/application addendum provided mailed to the  borrower from XXXX dated XX/XX/XXXX which acknowledges receipt of the Consumer Handbook on ARM mortgages and the ARM Disclosure at pg 54 #D0714. The date of XX/XX/XXXX is 1 day after the accepted initial application utilized for this loan. JF
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496698   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496698   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New Jersey Prepayment Penalty New Jersey Prepayment Penalty: No prepayment penalties are permissible in the state of New Jersey. Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496701   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Investment Purchase   C C C C C     No B
XXXX   3158496701   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158496702   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496702   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496702   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New York Prepayment Penalty New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496702   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496702   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to verify finance charge under disclosure due to missing TIL Itemization.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484249   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484249   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484249   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484249   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484249   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484249   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.               2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484249   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Disclosed payment on Note does not correspond with the loan amount, loan term, and interest rate on the loan.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484260   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496706   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-19): Exception remains, Document referenced does not appear to belong to exception.


Buyer Comment (2024-04-17): Appeal. Please see attached and D0294. Final TIL Disclosure dated XX/XX/XXXX and signed by the borrower on XX/XX/XXXX was found in file at the time of review.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496706   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496706   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496706   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484270   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484274   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484274   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-09): Document provided is Broker initial application. Alt source of app date was approved by client for loans missing Lender Initial application date. Exception remains.


Buyer Comment (2024-04-09): 04/09/2034 Appeal: Please see DOC D0134 for the Initial 1003 which is dated XX/XX/XXXX. DOC D0014 confirms the application date of XX/XX/XXXX. CK
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484274   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484274   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484274   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.               2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484274   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing an index of X.XX% and the lowest index within look back is X.XX%.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484274   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484281   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484281   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484281   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484281   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496713   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Connecticut Prepayment Penalty Test Connecticut Prepayment Penalty: A prepayment penalty is not permissible under the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act.  Prepay language states prepay will not exceed maximum permitted by applicable law.     Reviewer Comment (2024-04-16): The exemption from the prepayment penalty restriction established in the Mortgage Lenders, Correspondent Lenders, Brokers and Loan Originators Act is not a blanket exemption for all mortgage brokers. The mortgage broker or mortgage lender must meet one of the exemptions from licensure established in Section 36a-487 of the Act.  While XXXX meets exemption under 36a-487(a)(1), it is not clear if the lender in the request meet any of the exemptions listed in this section. Please provide information about how each of the lenders meets ones of the exemptions listed in Section 36a-487.
Exception remains.


Buyer Comment (2024-04-10): Cited prohibition is applicable to a mortgage broker. Prepayment penalty is payable to XXXX which is the lender per Sec. 36a-485. (Formerly Sec. 36-440). Definitions. (19)
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496713   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496713   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484302   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484302   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484302   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484310   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158484310   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158484315   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New York Prepayment Penalty New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484315   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484315   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484332   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484332   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484332   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484344   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484344   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484352   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484352   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484352   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496726   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No A
XXXX   3158484360   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Rate/Term   B B B B B     No B
XXXX   3158484360   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exempt from federal state and local high cost testing. Exception regraded to EV2-B.
        2 XX/XX/XXXX XX Investment Refinance - Rate/Term   B B B B B     No B
XXXX   3158484365   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484365   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496730   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496730   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exempt from federal state and local high cost testing.  Exception regraded to EV2-B.
        2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496733   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496733   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496733   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Commitment Letter  indicate the Index used was X.XX%. The minimum Index available in our look-back period is X.XX%.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484381   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484381   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484381   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA 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.     Reviewer Comment (2024-04-15): Exception remains, missing signed affiliated business disclosure from  XX/XX/XXXX from loan file.


Buyer Comment (2024-04-12): XX/XX/XXXX Please re-review pg 133 #D0169 which is the XXXX Price break down and reports the initial application  document date of Friday, XX/XX/XXXX reported on the  LAS. The ABA located at pg. 112 #D0154 is dated XX/XX/XXXX which is 3 business days later. The XXXX CBR located at pg. 171 #D0052 and XXXX GFE located at pg. 87 #D0143, all dated XX/XX/XXXX.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484381   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Til Itemization did not disclose of Prepaid Interest $305.22, Sign In Fee $200 as Prepaid Finance Charge.   Reviewer Comment (2024-04-18): While notary fees are excluded from finance charges and APR calculations, only the notary fee portion is excludable but signing fees and mobile services are not and these would be included as finance charges. Commentary to Regulation Z 1026.4(e)(1) provides:
1. Notary fees. In order for a notary fee to be excluded under §1026.4(e)(1), all of the following conditions must be met:
2. The document to be notarized is one used to perfect, release, or continue a security interest.
3. The document is required by law to be notarized.
iii. A notary is considered a public official under applicable law.
1. The amount of the fee is set or authorized by law.
If evidence can be provided verifying which portion of the "Sign-up/Notary Fee" was for notarizing documents as detailed above, that portion can be excluded from finance charges.


Buyer Comment (2024-04-16): 04-16-2024  Appeal.  AMC LASR shows a $200 Sign In fee which should not be included in PPFCs. $200 is the notary fee paid to a third party provider an shoulld be excluded from PPFCs. Removal of this fee will reduce FC into tolerance. MC
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484381   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496738   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496738   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496738   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New Jersey Prepayment Penalty New Jersey Prepayment Penalty: No prepayment penalties are permissible in the state of New Jersey. Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496738   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed TIL utilizing a lower index than available within look back. Lowest index within look back is X.XX%.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496741   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496741   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484395   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484395   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484395   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484395   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158484407   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484407   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484407   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484407   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496743   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Commitment Letter indicate the Index used was X.XX%. The closest Index available in our look-back period is X.XX%             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496743   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.               2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496743   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496743   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496743   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496743   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.     Reviewer Comment (2024-04-11): Exception remains, missing ARM disclosure from loan file.


Buyer Comment (2024-04-10): 04/10/2024 Appeal: Please see DOC D0188 which confirms the ARM disclosure was provided to the borrower. CK
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484419   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484419   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484419   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data (other than HUD-1 or Note) Payoff Statement Missing Missing Payoff Statement: Unable to determine if a prepayment penalty was included in the pay-off which may impact high cost findings.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484421   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No A
XXXX   3158484422   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484422   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484433   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Second Home Refinance - Rate/Term   B B B B B     No B
XXXX   3158484433   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Second Home Refinance - Rate/Term   B B B B B     No B
XXXX   3158484444   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484445   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158484445   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Provision) Arkansas High-Cost Loan (Certification of Counseling) Arkansas High-Cost Loan: No evidence of certification from a HUD-approved third party counselor that borrower has received counseling on the advisability of the loan transaction.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, and before any notice from borrower of compliance failure, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of mailing (must be in transit with courier).

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)  Within 60 days of closing, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) Letter of Explanation to borrower; (5) refund of amount over the high-cost threshold maximum; and (6) proof of mailing (must be in transit with courier).  Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     No C
XXXX   3158484445   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost) Arkansas High-Cost Loan (Points and Fees) Arkansas Home Loan Protection Act: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  X.XX% of the Total Loan Amount. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, and before any notice from borrower of compliance failure, provide: (1) Letter of Explanation; (2) refund of amount over the high-cost threshold maximum; and (3) proof of mailing (must be in transit with courier).

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)  Within 60 days of closing, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) Letter of Explanation to borrower; (5) refund of amount over the high-cost threshold maximum; and (6) proof of mailing (must be in transit with courier).  Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     Yes C
XXXX   3158484447   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (TX50(a)(6)) Texas Cash-out Loan  (TX Home Equity Disclosure/Notice Concerning Extensions of Credit Not Provided) Texas Constitution Section 50(a)(6): Missing date the Notice Concerning Extensions of Credit disclosure was provided, however file includes a signed acknowledgment stating that the owner(s) received the Notice at least 12 days prior to closing.     Reviewer Comment (2024-04-11): Please clarify the doc ID referring the owners notice.


Buyer Comment (2024-04-09): 04/09/2024 Concur with missing doc however the Owners Notice should suffice. DA
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term 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. B B B B B     Yes B
XXXX   3158484447   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure is due to TIL itemization did not disclose Settlement/Closing/Escrow Fee $150, Settlement/Closing/Escrow Fee $275, Tax Cert Fee $70.20 and is over disclosed with HUD Fee $420.20 as prepaid finance charge.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484447   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484448   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484448   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484464   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484464   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484464   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Wisconsin Prepayment Penalty Wisconsin Prepayment Penalty: Maximum prepay  allowed per state is 60 days interest calculated on 80% of the original loan amount ($XXXX).  Loan contracts for maximum calculated prepay of $XXXX, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484469   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484469   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484469   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484469   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.               2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484469   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing amortization schedule.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484486   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No C
XXXX   3158484486   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No C
XXXX   3158484486   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level (TX50(a)(6)) Texas Cash-out Loan (T-42 Endorsement Not Obtained) Texas Constitution Section 50(a)(6): Acceptable FNMA title insurance endorsements not obtained for home equity loan.  Although the loan file contains the T-42 Endorsement, there is no evidence the Title Policy includes the Texas T-42.1 endorsement. (The loan is a Texas Section 50 (a)(6) home equity loan.)               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other The endorsements would be required at the time of original title policy issuance, there is not an obvious remediation B B B B B     No C
XXXX   3158484486   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (TX50(a)(6)) Texas Cash-out Loan  (Loan closed prior to expiration of 12-day cooling off period) Texas Constitution Section 50(a)(6): Loan closed prior to the 12th day after the later of the application date or the date the Notice Concerning Extensions of Credit was provided.     Reviewer Comment (2024-04-10): Exception remains, application date XX/XX/XXXX and loan closed XX/XX/XXXX.


Buyer Comment (2024-04-09): 04/09/2024- Reference is made to D0207 Owner's Affidavit that specifically covers that the minimum 12 days issue.  Reference specifically Page 1 Notice, Application and Counting 12 Days Sections.  DA
        3 XX/XX/XXXX XX 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 C C C C     Yes C
XXXX   3158484486   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No C
XXXX   3158496760   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496760   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496760   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484503   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158484503   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484503   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484503   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-16): Exception remains, missing application date.


Buyer Comment (2024-04-12): 4/12/2024 Added Lender initial welcome and disclosure letter and file submission which reports lender file submitted same day as welcome letter. JF


Buyer Comment (2024-04-12): 4/12/2024 Please review the initial welcome/disclosure letter mailed to the borrower uploaded below. JF
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484503   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-16): Exception remains, missing application date.


Buyer Comment (2024-04-12): 4/12/2024 Please re-review pg. 98 #D1371 which is the Broker provided initial GFE dated XX/XX/XXXX. While the document is not lender provided the Borrower did sign for having received the Consumer Handbook on ARM Mortgages. JF
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496762   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496762   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496762   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496762   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484526   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484526   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484526   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-19): Unable to determine specific property type at time of Origination  (i.e. to include attached/detached for Single Family Dwellings) with documentation provided. Exception remains.


Buyer Comment (2024-04-18): 04-18-2024  Appeal.  Please find attached ValuSure AVM and Market Intelligence property condition report used to support property type as SFR. Please see 4 page trailing docs added 1:37pm 04-18. MC


Reviewer Comment (2024-04-17): Unable to determine if attached or detached from the documentation provided. Exception remains.


Buyer Comment (2024-04-17): The ValueSure Property Report previously provided is from origination; dated XX/XX/XXXX with a value of $XXXX used in the loan approval.


Reviewer Comment (2024-04-16): Exception remains, missing specific property type from origination.


Buyer Comment (2024-04-15): Please the attached origination AVM which indicates the subject property is a single family residence.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484526   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.     Reviewer Comment (2024-04-17): Exception remains, Exception generating due to Disbursement date on HUD XX/XX/XXXX.


Buyer Comment (2024-04-15): Please see RTC page 284 D0614 showing midnight of the 15th and Please see TIL page 65 D0615 dated XX/XX/XXXX. Saturday could not be included November 11 due to a Federal Holiday Veterans Day. I have attached the information for your review
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158484541   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484541   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484541   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.     Reviewer Comment (2024-04-15): Exception remains, The prepay language states that "if the then current interest rate I am required to pay is 8% or less", then the prepayment penalty is applicable. The prepayment penalty period is 12 months. The initial interest rate on this loan (that would be applicable in those first 12 months) is X.XX%, which therefore means the prepayment penalty is applicable to this loan.


Buyer Comment (2024-04-10): Appeal: PPP addendum is written such that the prepayment charge is only applicable if the current interest rate the borrower is required to pay is 8% or less
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484541   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484541   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Federal and State High Cost Lookback Failures Due to missing evidence of initial application date.  An application date of XX/XX/XXXX was used for Compliance testing.  The loan would result in a High Cost failure due to points and fees test failure based on the following application dates XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-15): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-10): 4/10/2024 Please re-review the following listed documents: Per the initial welcome letter from the Lender at pg. 85 #D0063, , the application had been submitted XX/XX/XXXX. Pg. 86 #D0145 is the Pre-Application Disclosure dated XX/XX/XXXX. Pg. 201 #D0025 is the CBR dated XX/XX/XXXX. The Facta at pg. 246 #D0061, the GFE at pg. 94 #D0136 and Initial TIL at pg. 96 #0133, all are dated XX/XX/XXXX. Initial Broker Application, Federal Truth in Lending, Pre-Application Disclosure and Broker GFE are all dated XX/XX/XXXX. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Provision) New York High-Cost Loan (Ability to Repay not Verified) New York High-Cost Loan:  Borrower’s ability to repay not verified with reliable documentation.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided) New York High-Cost Loan: Borrower not provided with Aggregate Monthly Payment Disclosure statement.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided) New York High-Cost Loan: Borrower not provided with Consumer Caution and Home Ownership Counseling Notice.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided) New York High-Cost Loan: Counseling Disclosure not provided to borrower.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold) New York High-Cost Loan: Lender financed points and fees in excess of 3% of the total loan amount.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage) New York High-Cost Loan: Mortgage does not contain legend advising loan is high-cost.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application) New York High-Cost Loan: Mandatory "Shop Around" Notice not included on loan application to applicant.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost) New York High-Cost Loan (Points and Fees) New York Anti-Predatory Lending Statute: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  5.00000% of the Total Loan Amount. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     Yes C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.     Reviewer Comment (2024-04-15): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-10): 4/10/2024 Please re-review the following listed documents: Per the initial welcome letter from the Lender at pg. 85 #D0063 the initial Lender application was submitted on XX/XX/XXXX and all disclosures were mailed. The CBR at pg. 201 #D0025, as well as the Pre-APP Disclosure at  pg. 86 #D0145, the FACTA at pg. 246  #D0061 as well as the Initial GFE at pg 94 #D0136 and initial TIL at  pg 96 # D0133 are also dated XX/XX/XXXX
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-15): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-10): 4/10/2024 Please re-review the following listed documents: Per the initial welcome letter from the Lender at pg. 85 #D0063 the initial Lender application was submitted on XX/XX/XXXX and all disclosures were mailed. The CBR at pg. 201 #D0025, as well as the Pre-APP Disclosure at  pg. 86 #D0145, the FACTA at pg. 246  #D0061 as well as the Initial GFE at pg 94 #D0136 and initial TIL at  pg 96 # D0133 are also dated XX/XX/XXXX
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No C
XXXX   3158484549   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes C
XXXX   3158496777   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496777   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-16): Unable to determine specific property type at origination. Exception remains.


Buyer Comment (2024-04-12): 2nd Appeal. Page 436 Doc ID 0293 Property Inspection Report was done XX/XX/XXXX which is  prior to origination and the subject photo from the inspection shows it's detached. LM


Reviewer Comment (2024-04-11): Unable to determine property type at time of origination. If SFR attached or detached. Exception remains.


Buyer Comment (2024-04-11): 4/11/2024: Appeal: Please reference the following: Page 32 Doc ID 0315 Loan Approval reflects property type as SFR using AVM value from page 393 Doc ID 0294. Page 436 Doc ID 0293 Property Inspection Report lists the Property Type as Single Family. Page 365 Doc ID 0277 Title Policy did not check  Condo or PUD Endorsements. Loan application Schedule of RE type of property is SFR. LM
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484555   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484555   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484555   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484557   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484558   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484558   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484558   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484558   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484558   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496784   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496784   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496784   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496784   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496784   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484592   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484592   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484592   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496793   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158496793   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-12): ARM disclosure reviewed with initial file and trailing provided. Disclosure available is dated XX/XX/XXXX.  Exception related to timing- not provided to the borrower within three (3) days of application. Exception remains.


Buyer Comment (2024-04-10): 04-10-2024 Appeal.  Please find ARM disclosure attached. MC
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496793   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496793   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Flood Certificate Error: Certificate Number was not provided.       Reviewer Comment (2024-04-22): Exception remains, missing flood certificate number from form received.


Buyer Comment (2024-04-18): The document currently opens when clicking on the trailing document uploaded at 3:59 pm  04-10-2024 1st page.  Please note the loan closed in XXXX and the flood certificate may look different than a modern day flood cert.  The document clearly identifies property address and Zone D and no flood insurance is required.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496794   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496794   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL Itemization did not disclose Loan Flood Certification (Life of Loan) of $16.50, Loan Origination Fee of $250.00, Settlement/Closing/Escrow Fee of $240.00 as prepaid finance charges.   Reviewer Comment (2024-04-10): Exception remains, Signed HUD in loan file does not list all fees except 2 as seller paid.


Buyer Comment (2024-04-09): 04-09-2024  Appeal.  There were pnly two PPFCs paid by the borrower, the $1,571.40 MIP and interest of $94.68. The other items were paid by the seller.  Please see attached for suport. MC
        2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496795   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA TIL APR Tolerance Irregular Transaction Truth In Lending Act: Final TIL APR of X.XX% is underdisclosed from calculated APR of X.XX% outside of 0.250% tolerance.               2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496795   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to lender disclosed MI dropping off after 36 months and calculated dropping off after 160 months.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496799   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Missing Document: Flood Insurance Policy not provided       Reviewer Comment (2024-04-09): Exception remains, Flood binder provided is post origination.


Buyer Comment (2024-04-08): flood policy uploaded


Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No B
XXXX   3158496799   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.     Reviewer Comment (2024-04-09): Exception remains, missing Notice of flood hazards from origination.


Buyer Comment (2024-04-08): See uploaded disclosure. ta
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496799   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496799   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496799   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496799   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158496799   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496799   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496801   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496801   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496801   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496801   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496801   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status Unable to determine if loan file contains CHARM Booklet due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484640   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158484640   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484640   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484640   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484640   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158484640   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No D
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No D
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No D
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No D
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.               3 XX/XX/XXXX XX Primary Purchase   D D D D D     No D
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No D
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.     Reviewer Comment (2024-04-09): Exception remains, missing Arm disclosure from loan file.


Buyer Comment (2024-04-09): Please see page D0024 for borrower certification of receipt of ARM loan disclosure statement.
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No D
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No D
XXXX   3158496802   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No D
XXXX   3158496805   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496805   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496805   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496808   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484653   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484653   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484653   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484654   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXXis underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Amount finance variance is due to missing Attorney fees of $750, Prepaid finance charge of $-41.1, Title courier fee of $25, Pick up fee of $325 as prepaid finance charge.

Conditional Loan Approval indicates the Index used by the lender was X.XX%. The Index available within the look-back period is X.XX%.
            2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484654   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484654   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.     Reviewer Comment (2024-04-08): Exception remains.  RTC eligible Disbursement date XX/XX/XXXX.  Date entered on RTC XX/XX/XXXX and Disbursed XX/XX/XXXX.The disbursement date should come from page one of the HUD. When page one is missing this information, we look for evidence of funding from the settlement agent. If none found, our system will use the “Interest From” date to be able to run compliance..


Buyer Comment (2024-04-05): Final HUD-1
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158484655   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Second Home Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484655   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484655   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL itemization did not disclose Title Courier/Messenger fee $45 Wire transfer fee $35, Wire/funding/disbursement fee $35 and  HUD 1 fee amount did not disclose  Settlement fee $210 and Tax research fee $31 as prepaid finance charge.             2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Other TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484655   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. The Flood Zone was determined on XX/XX/XXXX as per Flood Certificate hence the Lender provided Notice to Borrower for property being in flood hazard zone on XX/XX/XXXX which is less than 10 business days from the Note date.   Reviewer Comment (2024-04-08): Exceptions remains, The final rule provides that delivery of notice must take place within a “reasonable time” before the completion of the transaction. What constitutes “reasonable” notice may vary according to the individual circumstances of a transaction. The preamble to the final rule states that the agencies generally continue to regard ten days as a “reasonable” time interval. However, in all cases an institution should bear in mind that a borrower should receive notice timely enough to ensure that borrower had opportunity to obtain flood insurance.


Buyer Comment (2024-04-04): 04/04/2024 Appeal: Please see DOC D0475. Subject transaction is a Refinance with an application date of XX/XX/XXXX. The property is a Condo with the Master Policy (D0333) including the Flood coverage. Taking into consideration that the borrower was aware of the Flood Hazard and the coverage is provided under the master policy, XX/XX/XXXX (date on the disclosure) would be considered reasonable. CK
        2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484665   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484672   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484672   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484672   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158484674   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484674   XXXX XXXX XX/XX/XXXX Credit Title Lien Title Missing evidence of lien position on Other Financing. Lien Position: 2     Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158484674   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484674   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-23): Exception remains. Document referenced is not acknowledged by borrower's signature.


Buyer Comment (2024-04-23): Please see Initial 1003 pages 657-663 dated loan officer section XX/XX/XXXX taken by telephone lender XXXX it is also stamped XX/XX/XXXX. I have attached disclosures including Arm disclosure sent within the 3 days page 2-7 and please look at page 9 which list all the disclosures that were sent.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496811   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496811   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance City / Local Compliance State Defect (City High Cost Provision) Chicago Predatory Loan (Ability to Repay not Verified) City of Chicago Predatory Loan:  Borrower’s ability to repay not verified with reliable documentation.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance City / Local Compliance State Defect (City High Cost Provision) Chicago Predatory Loan (Negative Amortization Feature) City of Chicago Predatory Loan: Mortgage loan contains an impermissible negative amortization feature.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance City / Local Compliance State Defect (City High Cost) Chicago Threshold Loan (Points and Fees) City of Chicago Anti-Predatory Lending Ordinance: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  5.00000% of the City Total Loan Amount. Points and Fees total $XXXX on a City Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance County Compliance State Defect (County High Cost Provision) Cook County Predatory Loan (Ability to Repay not Verified) Cook County Predatory Loan:  Borrower’s ability to repay not verified with reliable documentation.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance County Compliance State Defect (County High Cost Provision) Cook County Predatory Loan (Negative Amortization Feature) Cook County Predatory Loan: Mortgage loan contains an impermissible negative amortization feature.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance County Compliance State Defect (County High Cost) Cook County Threshold Loan (Points and Fees) Cook County Predatory Lending Ordinance: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  5.00000% of the County Total Loan Amount. Points and Fees total $XXXX on a County Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) Illinois High Risk Home Loan (Consumer Caution Notice Not Provided) Illinois High Risk Home Loan:  Borrower not provided with Consumer Caution Notice.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation See any available cure under Illinois High-Risk threshold exception. C C C C C     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Provision) Illinois High Risk Home Loan (Ability to Repay not Verified) Illinois High Risk Loan:  Borrower’s ability to repay not verified with reliable documentation.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation See any available cure under Illinois High-Risk threshold exception. C C C C C     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) Illinois High Risk Home Loan (Mortgage Awareness Program ("MAP") Not Provided) Illinois High Risk Home Loan: Borrower not notified of right to participate in Mortgage Awareness Program ("MAP").               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation See any available cure under Illinois High-Risk threshold exception. C C C C C     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Provision) Illinois High Risk Home Loan (Negative Amortization Feature) Illinois High Risk Home Loan:  Mortgage loan contains an impermissible negative amortization feature.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation See any available cure under Illinois High-Risk threshold exception. C C C C C     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost) Illinois High Risk Home Loan (Points and Fees) Illinois High Risk Home Loan Act: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of the greater of 5.00000% of the Total Loan Amount and $XXXX XXXX. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX and $XXXX XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, provide:  (1) Lender Attestation to AMC attesting the lender has not received any notice from borrower of the failure; (2) Letter of Explanation; (3) refund of amount over the high-risk threshold maximum; and (4) proof of mailing (must be in transit with courier).

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)  Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) Letter of Explanation to borrower; (5) refund of amount over the high-risk threshold maximum; and (6) proof of mailing (must be in transit with courier).   Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     Yes C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-08): Exception remains, missing disclosure dated XX/XX/XXXX.


Buyer Comment (2024-04-05): Please see attached Disclosure letter dated XX/XX/XXXX and Application Addendum signed by the borrower's on XX/XX/XXXX.Attached HMDA W/S also confirms application date of XX/XX/XXXX.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No C
XXXX   3158496812   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158484678   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-08): No action


Buyer Comment (2024-04-05): 4/5/2024 Unable to locate initial application after review of Acuity and EIV. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484678   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New Hampshire Prepayment Penalty First Lien New Hampshire Prepayment Penalty:  Prepayment penalty terms on a first lien loan not printed in bold on the Note or Note Addendum.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484678   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.     Reviewer Comment (2024-04-08): No Action


Buyer Comment (2024-04-05): 4/5/2024 Unable to locate ARM loan program disclosure after review of Acuity and EIV. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484678   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.     Reviewer Comment (2024-04-08): No action


Buyer Comment (2024-04-05): 4/5/2024 Unable to locate Charm Handbook on Adjustable Rate Mortgages, Charm Booklet after review of Acuity or EIV. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484678   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484679   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Approval indicate the Index used was X.XX%. The minimum Index available in our look-back period is X.XX%.   Reviewer Comment (2024-04-08): Exception remains, Note and ARM rider indicate 0.125%.


Buyer Comment (2024-04-05): 4/5-Appeal:  Please review rounding for FIR.  Note indicated .125% however LAS Finance Charges indicate rounding of .001%.
        2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484679   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484679   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484681   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484681   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484681   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484682   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484682   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484684   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484684   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158484692   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484692   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484692   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.     Reviewer Comment (2024-04-19): Letter does not include copy of the ARM Disclosure. Exception remains.


Buyer Comment (2024-04-17): Appeal - See XXXX file # 0699068003 ARM Disclosure as per Disclosure Letter. - SO


Reviewer Comment (2024-04-16): Exception remains, missing ARM disclosure from loan file.


Buyer Comment (2024-04-12): Appeal - Broker application date XX/XX/XXXX with Lender application date XX/XX/XXXX per application addendum, HMDA and pricing sheet. ARM booklet provided XX/XX/XXXX, within 3 days of the application date. Trailing docs for appeal added to the CHARM exception.  – SO


Reviewer Comment (2024-04-08): Exception remains, missing disclosure from loan file.


Buyer Comment (2024-04-04): Appeal - Providing proof the borrower received the ARM disclosure on XX/XX/XXXX.  CG
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158484692   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of
Amount Financed.
            2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158484692   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484692   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496818   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496818   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158484702   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484705   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158484705   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Investment Purchase   C C C C C     No B
XXXX   3158484707   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484707   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484707   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484707   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158484707   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing RTC Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158496822   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Rate/Term   B B B B B     No B
XXXX   3158496825   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-05): Loan not subject to federal or state anti-predatory lending testing.  Exception regraded to EV2-B.


Reviewer Comment (2024-04-04): A Final HUD-1 is defined as a HUD-1 or HUD-1A document that is either signed by the borrower, stamped by the title company, or signed by the settlement agent depending on whether the property is located in an escrow state or non-escrow state. In an escrow state the Final HUD-1 may not be signed by the borrower but must be stamped by the title company or signed by the settlement agent at closing. The HUD-1 in file (and the same one provided with the cover letter) has a signature space for the Settlement Agent; however does not contain a signature or stamp. Due to APR and points and fees calculations required for high cost and various other anti-predatory lending regulations in scope, it is critical that a reliable source document is used as the basis for actual charges and costs at consummation used in compliance testing. Accordingly, the signature/stamp requirements previously discussed are the methods applied to ensure the HUD used for testing is the most updated and one acknowledged by the borrower/settlement agent as appropriate. When a HUD exception is cited, the exception is cited for visibility to indicate that compliance testing may not be conclusive if the HUD in file used for testing is estimated or not signed or stamped certified and not reflective of the final points and fees charged at consummation.
"


Buyer Comment (2024-04-04): Appeal – Letter attached from settlement agent certifying the HUD. - SO
        2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496825   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA 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.     Reviewer Comment (2024-04-08): Exception remains, Missing affiliated business disclosure disclosed at application date.


Buyer Comment (2024-04-05): Appeal – The Disclosure notice confirms that the ABA was sent to the Borrower(s) within 3 days of the application date. - SO
        2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484722   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484722   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484722   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-10): Exception remains, missing arm disclosure from initial application date.


Buyer Comment (2024-04-09): Disclosure Letter


Reviewer Comment (2024-04-09): Exception remains, missing arm disclosure from initial application date.


Buyer Comment (2024-04-05): Please see attached Disclosure Letter dated XX/XX/XXXX, which indicates the ARM Disclosure was provided within 3 business day of the application, XX/XX/XXXX.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484734   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158484734   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158484734   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   D D D D D     No D
XXXX   3158484734   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158484734   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No D
XXXX   3158484734   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158484734   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No D
XXXX   3158484743   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484743   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Closing / Title Loan Package Documentation Security Instrument is not on a FNMA/FHLMC form and does not contain the following clauses: Homestead Exemption Waiver               1 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484743   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484743   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New Jersey Prepayment Penalty New Jersey Prepayment Penalty:  No prepayment penalties are permissible in the state of New Jersey.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484758   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484758   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158484761   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496838   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496838   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-09): No action as per comment


Buyer Comment (2024-04-08): 4/8/2024 Unable to locate ARM loan program disclosure. JF
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496841   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496841   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496841   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-17): Exception remains, missing application date to determine timing..


Buyer Comment (2024-04-17): Appeal. According to D0082 letter, CHARM booklet was enclosed when the letter was sent to the customer.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484784   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data (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.     Reviewer Comment (2024-04-08): Exception remains, Document provided does not list lock dates.


Buyer Comment (2024-04-05): Please see attached for verification of rate which was used on all closing documents. This file was not a DU or LP approval so form is different.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484784   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484784   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484784   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Rhode Island Home Loan (Invoices for Third Party Fees Not in File - Unable to Determined if Bona Fide) Rhode Island Home Loan: No documentation in loan file to confirm third party fees listed on the HUD-1.     Reviewer Comment (2024-04-10): RI HLPA specifically exempts any national bank, federal savings bank, any “financial institution”, or wholly-owned subsidiaries thereof. RI exception eligible for downgrade to EV2-B.


Buyer Comment (2024-04-04): Appeal: Cited requirement is specific to a High Cost Home Loan which this is not.


Buyer Comment (2024-04-04): Appeal:  Please provide the exact regulatory reference for the confirmation requirement stated in the detail.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484794   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158484794   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158484794   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exception regraded to EV2-B.
        2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158484794   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance Misc. State Level Idaho Residential Mortgage Practices Act (Rate Lock Agreement Not Provided) Unable to test ID Rate Lock-In/Float Disclosure due to missing information.               2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158484803   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX UTD Purchase   C C C C C     No B
XXXX   3158484803   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX UTD Purchase   C C C C C     No B
XXXX   3158484803   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX UTD Purchase   B B B B B     No B
XXXX   3158484803   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Non-Required Data Unable to determine occupancy, compliance results were generated using a defaulted value of Primary.       Reviewer Comment (2024-04-23): Exception remains, appraisal stating owner occupied is the seller.


Buyer Comment (2024-04-23): Appeal.  The appraisal shows property is occupied.  PA


Reviewer Comment (2024-04-17): Exception remains, unable to determine occupancy at origination.


Buyer Comment (2024-04-17): Appeal. Please see D0280 according to XXXX Agent Desktop property is Primary.
        2 XX/XX/XXXX XX UTD Purchase   B B B B B     No B
XXXX   3158484803   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data (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.               2 XX/XX/XXXX XX UTD Purchase   B B B B B     No B
XXXX   3158484803   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX UTD Purchase   B B B B B     No B
XXXX   3158484803   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX UTD Purchase   B B B B B     No B
XXXX   3158484803   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX UTD Purchase   B B B B B     No B
XXXX   3158496849   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496849   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496849   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496849   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484821   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484821   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484821   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496857   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496869   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496869   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158496869   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484885   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484885   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484885   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496876   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496876   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496876   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496878   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Safe Act SAFE Act - Individual LO NMLS license status not approved Unable to test Individual Loan Originator license status due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496878   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Safe Act SAFE Act - Individual LO not licensed at time of application Unable to test Loan Originator license due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496878   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Safe Act SAFE Act - Individual LO NMLS does not match NMLS Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan Originator NMLSR information on loan documents does not match NMLSR.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496881   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Safe Act SAFE Act - Individual LO NMLS license status not approved Unable to test Individual Loan Originator license status due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496881   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Safe Act SAFE Act - Individual LO not licensed at time of application Unable to test Loan Originator license due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496881   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Safe Act SAFE Act - Individual LO NMLS does not match NMLS Secure and Fair Enforcement for Mortgage Licensing Act: Individual Loan Originator NMLSR information on loan documents does not match NMLSR.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496881   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Loan Amount on Final GFE Inaccurate RESPA (2010): Loan Amount on Final GFE does not match Note.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496881   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Initial Payment on GFE Inaccurate RESPA (2010): Initial payment on GFE does not match actual payment on loan.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496881   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) - 10% Tolerance With Cure RESPA (2010): 10% tolerance violation with evidence of cure provided on Final HUD-1.     Reviewer Comment (2024-04-22): Exception remains, subject exception is stating a 10% tolerance is cited but tolerance was cured.


Buyer Comment (2024-04-18): 4/18/4 - Appeal: see on pg 296 D 0017 of the file in Clarity Hud doc showing Title Insurance fee and Government Recording fee increase of more than 10%.. Attached is a system generated document showing highlighted of the Title Insurance fee $1,538 - $1,275.78 was paid by the lender and $262.22 was Cured.. also the $168 Recording fee was paid by the lender. Please review and rescind...eg


Buyer Comment (2024-04-18): System generated doc
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     Yes B
XXXX   3158496881   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158496881   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.     Reviewer Comment (2024-04-15): Exception remains, ABA from XX/XX/XXXX not signed


Buyer Comment (2024-04-11): 04/11/2024 Appeal: Please see the original ABA sent to the borrower on XX/XX/XXXX (DOC - D0424). The borrower executed the same document at closing (DOC - D0183) CK
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496884   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496884   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496884   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496884   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158496884   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158496884   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data (other than HUD-1 or Note) (Missing Data) Unable to determine if loan is a same lender refi (Circuit 2, 5, 7, 8, 9, 10 or DC) Original Lender was not able to be determined. Unable to determine if correct TILA rescission form was used. (H-8 Form was used and property is in the 2 nd, 5 th, 7 th, 8 th, 9 th, 10 th, or District of Columbia)               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496884   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to verify finance charge under disclosure due to missing TIL Itemization.   Reviewer Comment (2024-04-08): Exception remains, SitusAMC will, by default, consider a lender’s attorney fee to be a finance charge when there is no separate closing fee charged. Had there been a separate closing fee charged, we would treat a second attorney fee as a 4c7 fee under the assumption it was paid for the purpose of preparing loan-related documents (thereby allowing for the exclusion). Pursuant to 1026.4(a)(2)-2, if the creditor requires the use of a closing agent, then fees charged by the closing agent are included in the finance charge


Buyer Comment (2024-04-05): attorney invoice


Buyer Comment (2024-04-05): Appeal:  The NY Attorney fee was excluded from finance charges due to the attorney fee being a legal fee rather than a loan closing fee.  Based on the attached invoice, the lender excluded the $600 legal fee from finance charges.
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496887   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496887   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496887   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484902   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484902   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484915   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484915   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine finance charge variance due to missing itemization of amount financed.   Reviewer Comment (2024-04-08): Exception remains, Under disclosure is due to fees as the total payment variance is only $0.03.


Buyer Comment (2024-04-05): 04/05/2024 Appeal:  Please check rounding used for FIR on the finance charge calculation.  Per note rounding is .125% however LAS FC chart indicates .001% for FIR. CK
        2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496893   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496895   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496895   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496895   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-23): Exception remains. Document referenced is not acknowledged by borrower's signature.


Buyer Comment (2024-04-22): 04/22/2024 Sent Original 1003 dated by LO XX/XX/XXXX with Charm Appeal . Review pages 173-174 D0117 shows Charm booklet mailed to borrower as well Arm Loan program disclosure


Reviewer Comment (2024-04-19): D0105 dated XX/XX/XXXX - date of closing. Exception remains.


Buyer Comment (2024-04-17): ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure was provided to the borrower within three (3) days of application.
Document #: D0105
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496895   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-23): Exception remains. Document referenced is not acknowledged by borrower's signature.


Buyer Comment (2024-04-22): Please see Initial 1003 taking by phone dated by LO XX/XX/XXXX. Review pages 173-174 D0117 shows Charm booklet mailed to borrower as well as other disclosures XX/XX/XXXX


Reviewer Comment (2024-04-19): D0105 dated XX/XX/XXXX - date of closing. Exception remains.


Buyer Comment (2024-04-17): Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, was provided to the borrower within three (3) days of application. App date D0169 - (XX/XX/XXXX)
Receipt of CHARM Document #: D0105
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158496895   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496895   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158496895   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496897   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Missing Document: Mortgage Insurance Certificate (MIC) not provided       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158496897   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496898   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496898   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496898   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484932   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158484932   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158484932   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.     Reviewer Comment (2024-04-22): No action


Buyer Comment (2024-04-18): Disregard prior comment.


Buyer Comment (2024-04-18): Appeal:  refinance with same lender, but borrower did not receive any new advances.  PA
        2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158496907   XXXX XXXX XX/XX/XXXX Credit Disclosure Missing Document Disclosure XXXX Informed  Consumer Choice Disclosure is missing. Disclosure: XXXX - Informed Consumer Choice Disclosure (Government Documents)     Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No B
XXXX   3158496907   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496907   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496911   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496911   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496911   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496911   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496919   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496919   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496919   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496919   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed. There is a Seller credit on page one of HUD for $12,000 which is not itemized therefore excluded.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496920   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496920   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496920   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Maryland Interest and Usury Prepayment Penalty Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496920   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496920   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496922   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496922   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Maryland Interest and Usury Prepayment Penalty Maryland Prepayment Penalty: Maximum calculated prepay of $XXXX exceeds the state maximum of 2 months interest calculated on 2/3 of the original balance ($XXXX).               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496922   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496922   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496922   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496922   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496925   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496925   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496925   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158496925   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158496925   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158484981   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484981   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158484981   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.     Reviewer Comment (2024-04-08): Exception remains. TIL D0332 is checked as Final but is not signed and Finance Charge Box includes "e" for Estimate.
TIL D0333 is checked as Final and signed but sill includes "e" for Estimated in the Finance Charge box.


Buyer Comment (2024-04-05): Correction to previous comment - Appeal - Please reference D0332 - signed TIL dated XX/XX/XXXX marked as Final


Buyer Comment (2024-04-05): 4/5/2024 - Appeal - Please reference D0331 - TIL dated XX/XX/XXXX marked as Final.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496929   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496929   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496929   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496929   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486528   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486528   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486528   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496937   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-08): Flood cert provided is not from time of loan origination. Exception remains.


Buyer Comment (2024-04-05): Appeal - Providing Flood Cert.  CG


Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158496937   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data (Missing Data) Flood Hazard Zone Federal Compliance - (Missing Data) Flood Hazard Zone: Special Flood Hazard Zone indicator was not provided. The applicable flood zone related testing cannot be performed.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496937   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496937   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496938   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496938   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496938   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496938   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. Federal Flood Disclosure Timing not provided.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485008   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485008   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485008   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485025   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485025   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158485025   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485028   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-17): Unable to determine attached or detached from documentation provided. Exception remains.


Buyer Comment (2024-04-16): 4/16/2024: Appeal. Please see document in Clarity that evidences subject property was a single family residence and has not change since. The documents in Clarity to reference are: D0001, D0116, D0117, D0163. LL


Reviewer Comment (2024-04-12): Document provided not at time of Origination. Exception remains.


Buyer Comment (2024-04-10): 4/10/2024: Appeal. Please see document # D0122 in Clarity showing subject property is a single family residence. LL
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485028   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485028   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158485028   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485028   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485028   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485028   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485034   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485034   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158485034   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158485042   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485042   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158485042   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158485042   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485042   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485059   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485059   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158485059   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485059   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158485059   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496954   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496954   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496954   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496954   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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. Disclosure dated XX/XX/XXXX.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496955   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158496955   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-19): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.


Buyer Comment (2024-04-17): Found Initial 1003 dated XX/XX/XXXX. Doc #: D0557
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496955   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496955   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158496955   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496958   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496958   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496962   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496962   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXXin the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of
Amount Financed.
  Reviewer Comment (2024-04-17): Exception remains, The recording of a subordination agreement would not fall within the finance charge exclusions, specifically those exclusions related to security interest charges set forth in 12 CFR 1026.4(e). Further, see para 1(ii) to section 4(e) in the Commentary to Regulation Z, “ii. Charges not excludable. If the obligation is between the creditor and a third party (an assignee, for example), charges or other fees for filing or recording security agreements, mortgages, continuation statements, termination statements, and similar documents relating to that obligation are not excludable from the finance charge under this section.” The charge in question is a recording fee related to an agreement between the creditor and a third party for the subordination of a junior lien. Therefore, the charge is not excludable from the finance charge.


Buyer Comment (2024-04-15): 04-15-2024  Appeal.  AMC LASR includes $18.50 PPFC for Subordination Recording Fee.  However, this fee was paid to the county Clerk of the Circuit Court. It is listed as "Record Subordination Agreement" and paid to the clerk which means it is not a PPFC or recording Service Fee.  Removal of this fee from PPFCs will drop within tolerance level. Please review and advise. MC
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496962   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496962   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496964   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496964   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496964   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496966   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496966   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496966   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496966   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496970   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158496970   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496970   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496970   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496972   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158496972   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485109   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485109   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496977   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496977   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485116   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL Itemization did not disclose Settlement/Closing/Escrow Fee of $200.00 as prepaid finance charges.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485116   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.     Reviewer Comment (2024-04-09): Exception remains, e next to the finance charges


Buyer Comment (2024-04-09): Please see page D0166 for final TIL.  Please advise as to what markings are being referenced.  Thank you for your help.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485124   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to identify the TIL Finance Charge Tolerance due to itemization is missing.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485124   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485124   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496984   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496984   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496984   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496984   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158496987   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158496987   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496987   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.   Reviewer Comment (2024-04-22): Exception remians, The Notice of Settlement is a fee charged in the state of NJ (NJ Rev Stat 46:26A-11) to record/document a notice that a specified property is being mortgaged by specified parties (consumer and lender) in order to ensure clear title in preparation for the recording of the security instrument. As such, the fee could arguably fall under §1026.4(c)(7) i and ii which are charges excluded from the finance charge. I've applied an offset for this fee.
The $50 Cancel Mortgage Fee is not being included in our finance charge calculation. The other fees included are as follows: $875 Attorney's Fee, $370 Commitment Fee, $5 Flood Cert Fee, $1,065.24 Prepaid Interest, $84 Tax Service Fee, $50 Title Courier, and $25 Wire Fee.
With the offset for the Notice of Settlement Fee, the finance charge is now underdisclosed by $XXXX.


Reviewer Comment (2024-04-22): EXCEPTION HISTORY - Exception Detail was updated on 04/22/2024 PRIOR Exception Detail: Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $482,475.01 in the amount of $92.56.


Buyer Comment (2024-04-19): Appeal:  $40 Notice of Settlement is a required recording fee in NJ to file the NOS.  It is correctly placed in the 1200 section and is not a prepaid.  The $50 Cancel Mortgage charge is also a cost to record the mortgage cancellation after payoff.  It is correctly placed in the 1200 section and is not a prepaid.
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496987   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496987   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158496991   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158496991   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158496991   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485139   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485139   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485139   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine finance charge variance due to missing itemization of amount financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485139   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485149   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158485149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.   Reviewer Comment (2024-04-15): Exception remains, Association fee on HUD is paid to Lender.


Buyer Comment (2024-04-11): 4/10/2024: Appeal. Unable to proceed with review of exception need more information. The "Other 1" in the amount of $50 in LAS, is reflected on 814 and the charge is for Association fee, not a lender fee and is not a prepaid finance charge. $18 reflected on LAS as Assignment recording fee on line 1205 is not a prepaid finance charge. Please re-review charges for finance charge. LL
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485149   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158497002   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485162   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485162   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Incorrect Right To Cancel Form Used - H-9 Used on Non Same Lender Refinance Truth in Lending Act: Notice of Right to Cancel was not executed on the proper Model Form for a refinance by a creditor that is not considered the original creditor. The H-9 form was used, the H-8 form should have been used.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158485162   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158497006   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.     Reviewer Comment (2024-04-08): No action. Comment provided as unable to locate.notice.


Buyer Comment (2024-04-05): 4/5/2024 Unable to locate a Notice of Special Flood Hazard Disclosure in Acuity or EIV
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497006   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485177   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485177   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485177   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485187   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data (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.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485187   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485194   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.       Reviewer Comment (2024-04-08): Exception remains. SitusAMC looks for the borrower’s signature date on the TIL to confirm borrower’s receipt of the required disclosures before loan consummation. Further, on rescindable transactions, the TIL signature date is used as the basis for date of receipt of material disclosures for purposes of determining one of the 3 dates triggering when rescission period begins.


Buyer Comment (2024-04-05): Appeal - Signed TIL is dated XX/XX/XXXX on top of page.  CG
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485203   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Borrower signature not dated.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485203   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect South Carolina Home Loan (Complaint Agency Disclosure Not Provided) South Carolina Home Loan: Borrower not provided with a document specifying the agency designated to receive complaints or inquiries about the origination and making of the loan.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     Yes B
XXXX   3158485203   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Right of Rescission Timing - Receipt Date Missing Missing Final TIL Signature Date. Unable to determine compliance with rescission timing requirements.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission B B B B B     Yes B
XXXX   3158497032   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497032   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497032   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158485226   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485226   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485226   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497049   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497049   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497056   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497056   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497056   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158497059   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158497059   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497059   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497059   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497061   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497061   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497061   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497061   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497066   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158497066   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data (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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Federal and State High Cost Lookback Failures Due to missing evidence of initial application date.  An application date of XX/XX/XXXX was used for Compliance testing.  The loan would result in a High Cost failure due to points and fees test failure based on the following application dates XX/XX/XXXX, XX/XX/XXXX.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-16): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.


Buyer Comment (2024-04-15): Please the attached initial application which was taken over the phone on 4/9/2008.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Aggregate Payment Disclosure Not Provided) New York High-Cost Loan: Borrower not provided with Aggregate Monthly Payment Disclosure statement.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Consumer Caution and Home Ownership Counseling Notice Not Provided) New York High-Cost Loan: Borrower not provided with Consumer Caution and Home Ownership Counseling Notice.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Counseling Disclosure Not Provided) New York High-Cost Loan: Counseling Disclosure not provided to borrower.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Provision) New York High-Cost Loan (Financed Fees Exceeds Threshold) New York High-Cost Loan: Lender financed points and fees in excess of 3% of the total loan amount.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (High Cost Legend Not on Mortgage) New York High-Cost Loan: Mortgage does not contain legend advising loan is high-cost.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost Disclosure) New York High-Cost Loan (Shop Around Notice Not on Loan Application) New York High-Cost Loan: Mandatory "Shop Around" Notice not included on loan application to applicant.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No obvious cure C C C C C     No C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect (State High Cost) New York High-Cost Loan (Points and Fees) New York Anti-Predatory Lending Statute: Points and Fees on subject loan of X.XX% is in excess of the allowable maximum of  5.00000% of the Total Loan Amount. Points and Fees total $XXXX on a Total Loan Amount of $XXXX vs. an allowable total of $XXXX (an overage of $XXXX or X.XX%).  Non-Compliant High Cost Loan.     Reviewer Comment (2024-04-19): SitusAMC included the $210 patriot search fee in both the finance charge calculation and the NY points and fees test. As noted previously, patriot search charges do not fall under a specific exemption for finance charges under 1026.4 and are therefore included as a finance charge. SitusAMC does not consider a Patriot Act Search fee to fall under “similar purposes” as it relates to treating the fee along with real estate related title fees under 1026.4(c)(7). The Patriot Act applies to all financial institutions and non-bank loan companies and requires entities to identify, verify and record a borrower’s identity and requires private financial information be released to the government. It is not generally a component of title insurance.
 
As it relates to New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans, finance charges are included in the high cost points and fees definition under (f)  All items listed in 15 U.S.C. § 1605(a)(1) through (4), except interest or the time-price differential.


Buyer Comment (2024-04-16): Please detail under which section of NY Banking Law 6-L(f) "Points and Fees" a patriot act search would fall.


Reviewer Comment (2024-04-16): We respectfully disagree that a Patriot Act Search fee would fall under “similar purposes” as it relates to treating the fee along with other title fees under 1026.4(c)(7) . The Patriot Act applies to all financial institutions and non-bank loan companies and requires entities to identify, verify and record a borrower’s identity and requires private financial information be released to the government. It is not generally a component of a title insurance. Patriot search charges do not fall under a specific exemption for finance charges under 1026.4 and is therefore included as a finance charge. Exception remains


Buyer Comment (2024-04-11): It falls under "similar purposes" in 1026.4(c)(7)(i) and was paid to the title company (XXXX). If AMC disagrees please detail under which section of NY Banking Law 6-L(f) "Points and Fees" a patriot act search would fall under.


Reviewer Comment (2024-04-11): Exception remains, The Patriot Act applies to all financial institutions and non-bank loan companies and requires entities to identify and verify and record borrowers identities and requires private financial information be released to the government. It is not generally a component of a title insurance or title exam. Patriot search charges do not fall under a specific exemption for finance charges under 1026.4 and are therefore included as a finance charge.


Buyer Comment (2024-04-09): Search fees are not prepaid finance charges and should not be included in the NY test.


Reviewer Comment (2024-04-09): Patriot Search $210.00 and Title Courier Fee $75.00 HUD Line # 1113 Itemized on Closing Statement D0156.. Exception remains.


Buyer Comment (2024-04-08): Please detail the corresponding HUD line numbers for the $75 Courier Fee and $210 Other 1 fee contained on the LAS.
        3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation Within 30 days of closing, provide: (1) Signed letter from borrower indicating their choice to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (2) Assuming option (a) is selected, a copy of refund check and proof of mailing (must be in transit with courier); (3) Assuming option (b) is selected, proof of cure for each of the prohibited practice violations noted.

(Limited Use Bona Fide Errors - Compliance and Client Approval Required)   Within 60 days of discovery, provide:
(1) Legal opinion from originating lender with loan-specific details on how a high-cost loan was made despite procedures to prevent and confirms (i) the failure constitutes a bona fide error for the jurisdiction in which the property is located, and (ii) that the lender has not received any notice from the borrower of the failure; (2) procedures or explanation of controls in place to prevent such errors; (3) client written approval accepting use of the bona fide error cure; (4) signed borrower choice letter to either (a) accept refund and make loan non-high-cost or (b) keep loan as high-cost and make loan compliant; (5) If option 4(a) is selected, copy of refund check and proof of mailing; (6) If option 4(b) is selected, proof of cure for each of the prohibited practice violations. Note, a cure may not be accepted if the seller/lender has certified a fix has been made to their system and the same issue continues to occur after the fix has been put into place.
C C C C C     Yes C
XXXX   3158497071   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.   Reviewer Comment (2024-04-19): SitusAMC included the $210 patriot search fee in both the finance charge calculation and the NY points and fees test. As noted previously, patriot search charges do not fall under a specific exemption for finance charges under 1026.4 and are therefore included as a finance charge. SitusAMC does not consider a Patriot Act Search fee to fall under “similar purposes” as it relates to treating the fee along with real estate related title fees under 1026.4(c)(7). The Patriot Act applies to all financial institutions and non-bank loan companies and requires entities to identify, verify and record a borrower’s identity and requires private financial information be released to the government. It is not generally a component of title insurance.
 
As it relates to New York Consolidated Laws, Banking Law - BNK § 6-l. High-cost home loans, finance charges are included in the high cost points and fees definition under (f)  All items listed in 15 U.S.C. § 1605(a)(1) through (4), except interest or the time-price differential.


Buyer Comment (2024-04-17): The fee of $210 for Patriot Search, which is include in the total of $620 on the Final HUD-1 is not a Prepaid Finance Charge and therefore should not have been included in the calculation. Please escalate.


Reviewer Comment (2024-04-16): Exception remains, Other charge is for a patriot search.


Buyer Comment (2024-04-15): AMC included $210 in Other Fee and $75 Courier fee which are not reflected on the Final HUD-1. The Escrow Deposit for open water charge of $188 should not be included in The Other Fee amount. Please provided details for charge described as "Other".
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes C
XXXX   3158497072   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-03-29): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158497072   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497072   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497074   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge Louisiana Late Charge Percent Testing Louisiana Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 5%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497074   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497074   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure Notice of Special Flood Hazard Disclosure Missing FDPA Notification Rule: Creditor did not provide a Notice of Special Flood Hazard Disclosure for property located in a flood zone.     Reviewer Comment (2024-04-03): Exception remains, missing disclosure from origination.


Buyer Comment (2024-04-02): 4.2.24 Appeal loan closed XX/XX/XXXX with flood insurance policy pXXXX, no escrow loan and not required at that time, Notice of special Flood p129-2796 sent to borrower -Borrower had elevation certificate completed in XXXX page 69-74of2796 -D0414- kindly review resind.gs.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497074   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497074   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497074   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exception regraded to EV2-B.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-08): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-04): 04-04-2024  Appeal 2. Re-loading 5 page appeal document. Page 1 = Truth in Lending Input Record showing XXXX and Application date XX/XX/XXXX. Page 2 Underwriting Loan Cover Sheet showing application date is XX/XX/XXXX and underwriter name is XXXX.  Page 3-4 is XXXX Underwriting Approval showing UW name is XXXX and that she approved loan on XX/XX/XXXX. Page 5 is DU pulled by XXXX on XX/XX/XXXX.  The appilication date of XX/XX/XXXX is supported. MC


Reviewer Comment (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-02): 04-02-2024  Appeal.  The lender application date is adequately supported on the Truth in Lending Input Record and Underwriting Loan Coversheet as XX/XX/XXXX. There is no lender 1003, but the application date is supported. Please see attached documents. MC
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-08): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-04): 04-04-2024  Appeal 2. Re-loading 5 page appeal document. Page 1 = Truth in Lending Input Record showing XXXX and Application date XX/XX/XXXX. Page 2 Underwriting Loan Cover Sheet showing application date is XX/XX/XXXX and underwriter name is XXXX.  Page 3-4 is XXXX Underwriting Approval showing UW name is XXXX and that she approved loan on XX/XX/XXXX. Page 5 is DU pulled by XXXX on XX/XX/XXXX.  The appilication date of XX/XX/XXXX is supported. MC


Reviewer Comment (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-02): 04-02-2024  Appeal.  The lender application date is adequately supported on the Truth in Lending Input Record and Underwriting Loan Coversheet as XX/XX/XXXX. There is no lender 1003, but the application date is supported. Please see attached documents. MC
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158485298   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-08): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-04): 04-04-2024  Appeal 2. Re-loading 5 page appeal document. Page 1 = Truth in Lending Input Record showing XXXX and Application date XX/XX/XXXX. Page 2 Underwriting Loan Cover Sheet showing application date is XX/XX/XXXX and underwriter name is XXXX.  Page 3-4 is XXXX Underwriting Approval showing UW name is XXXX and that she approved loan on XX/XX/XXXX. Page 5 is DU pulled by XXXX on XX/XX/XXXX.  The appilication date of XX/XX/XXXX is supported. MC


Reviewer Comment (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-02): 04-02-2024  Appeal.  The lender application date is adequately supported on the Truth in Lending Input Record and Underwriting Loan Coversheet as XX/XX/XXXX. There is no lender 1003, but the application date is supported. Please see attached documents. MC
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158497083   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497083   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497083   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158497083   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158485318   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485321   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485321   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485323   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485323   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158497093   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-03): Exception remains, application referenced is not dated and alt documents must state application date.


Buyer Comment (2024-04-03): 4.3.24 Appeal attached Initial hand written/typed 1003 taken by telephone -AMC p58-61of1347 -D0178- GFE p92of1347 -D 0097- dated prepared printed XX/XX/XXXX  signed XX/XX/XXXX date stamped XX/XX/XXXX-all disclosures the same infile kindly review rescind.gs.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497098   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing itemization of amount financed.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158497098   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158497098   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485343   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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).               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158485343   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485343   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485343   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158485349   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485349   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUS AMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486608   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485363   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485363   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. under disclosure due to itemization not disclosing an origination fee in the amount of $XXXX and disclosing a settlement closing fee in the amount of $1,846 and HUD disclosing a settlement closing fee in the amount of $1,150.   Reviewer Comment (2024-04-16): Exception remains, HUD does not list the origination fee as broker paid and no credit from broker on page 1 of HUD.


Buyer Comment (2024-04-15): closing instructions


Buyer Comment (2024-04-15): Appeal:  Attached please find the subject loan closing instructions showing the loan origination fee of $XXXX paid to lender is paid by the mortgage broker.
        2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158486638   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486638   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486638   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-03): Exception remains.   Received stamp on broker application  not accepted alt source application date. Application date per the review XX/XX/XXXX.


Buyer Comment (2024-04-02): 4.2.24 Appeal page163of3755-D0802 XXXX application received date stamped XX/XX/XXXX application taken by telephone, mailed Arm disclosure dated XX/XX/XXXX page 507of3755-D0431-application disclosure dated XX/XX/XXXX page 285-of3755 D0428, Note date XX/XX/XXXX brokered loan kindly review rescind.gs.
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158486638   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.     Reviewer Comment (2024-04-03): Exception remains.  TIL provided with appeal is dated and signed prior to closing.  Final TIL in file dated XX/XX/XXXX and signed date of closing.


Buyer Comment (2024-04-02): 4.2.24 Appeal attached your page 312of3755-D 0794 final signed TIL dated XX/XX/XXXX signed XX/XX/XXXX and p310of3755-D 0792-Initial Prelim TIL, our borrower XXXX Friday property XXXX kindly review rescind.gs.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497115   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Final TIL Estimated Final TIL Estimated Final TIL disclosure found in file had markings indicating one or more entries are estimates.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497115   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485374   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New York Prepayment Penalty New York Prepayment Penalty: Max prepay term allowed on an adjustable rate loan greater than $XXXX is 12 months.  Loan contracts for prepay term of 36 months, which exceeds max allowable.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485374   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data (other than HUD-1 or Note) (Missing Data) Unable to determine if loan is a same lender refi (Circuit 2, 5, 7, 8, 9, 10 or DC) Original Lender was not able to be determined. Unable to determine if correct TILA rescission form was used. (H-8 Form was used and property is in the 2 nd, 5 th, 7 th, 8 th, 9 th, 10 th, or District of Columbia)               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485374   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485380   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485384   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485384   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485390   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Disclosed payment on note of $  does not correspond with the loan amount, loan term and interest rate on the loan.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485390   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485407   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485407   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485409   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485409   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485409   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158485409   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Conditional Loan Approval indicates the Index used by the lender was X.XX%. The Index available within the look-back period is X.XX%.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485431   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485431   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485441   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485441   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497130   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497130   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497130   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exception regraded to EV2-B.
        2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497130   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data (other than HUD-1 or Note) Disparity in Occupancy - Not High Cost and Not Higher Priced The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Investment).     Reviewer Comment (2024-04-02): Exception remains, Page 1 of application is referencing an investment property and page 3 of application states borrower intended to occupy property as primary.


Buyer Comment (2024-04-01): 4.1.24 Appeal attached page 51of792 XXXX counter offer approval shows borrower applied for as an investment property was not currently living in property at time of 1003,  locked as an investment property, page 92-95of792 Occupancy affidavit I will not occupy the property- page 147-792 -locked in as a NON-Owner/Investment. Closed as primary residence -Appraisal shows primary residence. P362of792 kindly review and rescind.gs.
        2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485447   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497132   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497132   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158497132   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485454   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Second Home Refinance - Rate/Term   B B B B B     No B
XXXX   3158485484   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485484   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497146   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497146   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exception regraded to EV2-B.


Reviewer Comment (2024-04-02): Exception remains. In a non-escrow state the Final HUD-1 must be signed by the borrower at closing


Buyer Comment (2024-04-02): 04/01/2024 Appeal: Please see Doc D0030. The Final HUD is signed by the Settlement Agent and marked as Certified to be a true copy. CK
        2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497146   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497148   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497148   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exception regraded to EV2-B.


Reviewer Comment (2024-04-02): Exception remains. HUD page 2 includes Funds Held and purpose not provided.


Buyer Comment (2024-04-01): 04/01/2024 Appeal: Please see DOC D0127 for the Final HUD1 which is stamped and executed by the settlement agent. CK
        2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497148   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485506   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485506   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485535   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485535   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158485535   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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 (2024-04-03): Exception remains.  Missing acknowledgement of receipt of the CHARM
Disclosure from the borrower or evidence that the disclosure was sent to the borrower.
In order to be considered acceptable, an acknowledgement of receipt must be dated, confirm
receipt of the disclosure and be signed by the borrower.


Buyer Comment (2024-04-03): .


Buyer Comment (2024-04-03): see attached


Reviewer Comment (2024-04-02): Acknowledgement in file dated XX/XX/XXXX. Please provide document to support the XX/XX/XXXX per comment.


Buyer Comment (2024-04-02): 4/2-Appeal: HMDA form reflects application date of XX/XX/XXXX, the CHARM Booklet was provided within 3 business days of application date on XX/XX/XXXX.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158485535   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485535   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. It appears Lender used an index outside of the lookback period. the lowest Index available in our look-back is X.XX%.   Reviewer Comment (2024-04-03): Exception remains. Underdisclosure appears to be related to the payment stream variation. It appears the lender used an index lower than X.XX%%%, which is the lowest rate in the look back period. .


Buyer Comment (2024-04-03): Appeal : Following Fees were included in the PPFC, Origination Fee $6,070.00 + Funding/Review Fee+ $355.00Tax Service +$81.00 +Wire Transfer $35.00
+ Flood Cert LOL $8.00 + Processing Fee $686.00 +File Storage Fee $59.00 + Daily Interest -$27.42(credit) +Settlement/Closing Fee $300.00 +Recording Processing Fee $30.00 +Shipping/Handling  $90.00.  Signing(Notary)Fee and Payment processing fee are not prepaid finance charges. TC


Reviewer Comment (2024-04-02): Comment updated in connection with Underdisclosed amount. Removed Disclosed payment on note of $XXXX does not correspond with the loan amount, loan term and interest rate on the loan.


Buyer Comment (2024-04-02): 4/2-Appeal: Payment on the Note dated XX/XX/XXXX is $XXXX please advise where payment of $XXXX is appearing.
        2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485535   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485555   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485555   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485560   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-03-29): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158485560   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497165   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497165   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497170   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Rate/Term   B B B B B     No B
XXXX   3158497171   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485604   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-03-29): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No D
XXXX   3158485604   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158485604   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   D D D D D     No D
XXXX   3158485604   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158485608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485608   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL itemization did not disclose an Email/ E-doc of $50, Settlement fee of $245 and Wire fee of $30, Tittle Courier Fee,$120 as prepaid finance charge.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485608   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497178   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497178   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497178   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Exception regraded to EV2-B.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497178   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Disclosed payment on note of $XXXX does not correspond with the loan amount, loan term and interest rate on the loan.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485625   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485625   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485627   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485627   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485627   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-11): Exception remains, HUD in referenced rebuttal is estimated as per line 903.


Buyer Comment (2024-04-09): D0005 was stamped/signed by the settlement agent (bottom of pages 1 and 2). Please review to Clear/EV1.


Reviewer Comment (2024-04-09): Exception regraded to EV2-B.


Buyer Comment (2024-04-09): D0005 was stamped/signed by the settlement agent (bottom of pages 1 and 2).
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497182   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497182   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486648   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486648   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485641   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485641   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497184   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Second Home Refinance - Rate/Term   B B B B B     No B
XXXX   3158497184   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Second Home Refinance - Rate/Term   B B B B B     No B
XXXX   3158497186   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158497186   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497186   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485653   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485653   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485653   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158485657   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485657   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158485657   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485659   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485665   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing..             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497192   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-03): Exception remains. Missing Final 1003 Application.


Buyer Comment (2024-04-02): 4.2.24-Appeal Initial application page43-50-1324-D0075 (2copies) signed by borrowers and LO was all that was required in XX/XX/XXXX Note date XX/XX/XXXX kindly advise.gs


Reviewer Comment (2024-03-29): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158497192   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485675   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485675   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485675   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158497198   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Second Home Refinance - Rate/Term   B B B B B     No B
XXXX   3158497198   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Second Home Refinance - Rate/Term   B B B B B     No B
XXXX   3158497198   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data (other than HUD-1 or Note) Disparity in Occupancy - Not High Cost and Not Higher Priced The mortgage loan file contains documenting evidence the consumer intends to occupy the subject property as their primary residence. (Compliance testing performed based on the Occupancy Type of Second Home).               2 XX/XX/XXXX XX Second Home Refinance - Rate/Term   B B B B B     No B
XXXX   3158485680   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485680   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158485683   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485683   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158497205   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497205   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Second Home Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485708   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-03-29): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158485708   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485708   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485708   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485708   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158485708   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158485713   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485713   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes B
XXXX   3158485728   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Second Home Purchase   B B B B B     No B
XXXX   3158485775   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485775   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485786   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485786   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497218   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497218   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497218   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485800   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485800   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485806   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486708   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485821   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485821   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485825   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485825   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158497225   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Disclosure 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.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158497225   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485836   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485836   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New Jersey Prepayment Penalty New Jersey Prepayment Penalty: No prepayment penalties are permissible in the state of New Jersey. Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485842   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485842   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485842   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect Illinois Prepayment Penalty Illinois Prepayment Penalty (Illinois Interest Act): A prepayment penalty is not permissible on a loan with an interest rate of greater than 8%. Loan contracts for an interest rate of X.XX%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485842   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158485842   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158485842   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form 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.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158485871   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Purchase   B B B B B     No B
XXXX   3158486718   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486718   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486718   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486718   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486718   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158485874   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485874   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   C C C C C     No B
XXXX   3158485874   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158485885   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485887   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-03): No action appeal cancelled


Buyer Comment (2024-04-03): 4.3.24 Please cancel this appeal request. Thank you gs.


Buyer Comment (2024-04-03): part 2.


Buyer Comment (2024-04-03): 4.3.24 Appeal-borrower was not at closing had a AttorneyInFact-POA sign Note date XX/XX/XXXX,
Attached final loan application signed-wet signature by borrower and marked “final” XX/XX/XXXX -AMC file page26of2491- D 0429. Attached initial 1003 stamp received date XX/XX/XXXX.AMC accepting broker now.kindly review and rescind.gs


Reviewer Comment (2024-03-29): Per client request.
        2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158485887   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158485887   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158497237   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497237   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158497237   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485897   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485897   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158485898   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-15): Exception remains, missing final 1003


Buyer Comment (2024-04-11): 4-11-24 APPEAL, Providing final Addendum to loan application.  /dp


Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   C C C C C     No B
XXXX   3158485898   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Unable to determine under disclosure due to missing Itemization of Amount Financed.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158485898   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Notice of Right to Cancel Expiration Date Prior or equal to Disbursement Date Unable to test RTC expiration date due to missing information.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158485898   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form (Doc Error) RTC Error:  Right to Cancel expiration date is blank.                 2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158497239   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-02): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158497239   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497239   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Creditor did not provide Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497247   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-03): Exception remains. Reviewed Broker with a stamp Final with reference to comments. Document provided is not signed by the borrower(s).


Buyer Comment (2024-04-02): 04-02-2024  Appeal.  In 2023 AMC had agreed to accept the Broker's Final 1003 as the final 1003.  The Lenders 1003 was not required as pertains to the Final 1003. Acuity contains the brokers initial and final 1003s and both are stamped for identification.  Has this policy changed?  It is acknowledged that there are no Lender 1003s in the loan file, only Broker 1003s are present.  Pleasee advise, thank you.  MC


Reviewer Comment (2024-03-29): Per client request.
        2 XX/XX/XXXX XX Primary Purchase   C C C C C     No B
XXXX   3158497247   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497247   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL Itemization did not disclose a Settlement fee $1,500.00  as prepaid finance charge.
Over disclosure of finance charge is due to TIL payment stream
  Reviewer Comment (2024-04-04): Exception remains, Attorney fee is charged on line 1107 in the amount of $750.00.


Buyer Comment (2024-04-03): 04-03-2024 2nd Appeal. Please note, AMC LASR shows a $750 fee listed in PPFCs which is shown as an attorney fee.  The only $750 fee listed on the HUD1 is for the Survey fee on line 1301. This should be excluded from PPFCs.  The itemization is not adding fees adding fees to the HUD1; it seems to be re-grouping them and has an "E" next to them.  The PPFCs should be taken from the HUD1. Please review and advise. MC


Reviewer Comment (2024-04-02): Exception remains, under disclosure is due to TIL itemization disclosed a settlement closing fee in the amount of $1,500 ( which seems to be all the prepaid finance charge title charges) Total of title prepaid finance charges is $1,514.97. ($14.97 not disclosed on itemization) Application fee in the amount of $495.00 should be included in prepaid finance charges but not. Survey fee not included in prepaid finance charge calculation.


Buyer Comment (2024-04-01): 04-01-2024  Appeal.  AMC LASR is including  the ($750 HUD1 line 1301) survey fee in PPFCs which should be excluded. Please review and advise. AMC notes mention a $1,500 settlement fee that was not included. Lender was unable to locate this fee on the HUD1. Please specify by HUD1 line number if this is insufficient to resolve. MC
        2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158497247   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA Federal FACTA Disclosure Timing Test FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure within a reasonably practicable time after using credit score.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486004   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-03-29): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158486004   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486004   XXXX XXXX XX/XX/XXXX Compliance Loan Package Documentation Closing / Title Loan Package Documentation (Doc Error) TIL Error: Final TIL not signed by all required parties                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486004   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486004   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486014   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No D
XXXX   3158486014   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  HUD-1 Not Signed or Stamped Used For Fee Testing Material Missing Final HUD-1:  HUD-1 Not Signed or Stamped used for any applicable Federal, State or Local compliance testing.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   D D D D D     No D
XXXX   3158486014   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-02): Document provided is Broker initial application. Alt source of app date was approved by client for loans missing Lender Initial application date. Exception remains.


Buyer Comment (2024-04-02): See 1003 upload, pls cclear
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No D
XXXX   3158486014   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No D
XXXX   3158486014   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No D
XXXX   3158486021   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486021   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486021   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486021   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486021   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158486021   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158497255   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497255   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497255   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158497255   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158497255   XXXX XXXX XX/XX/XXXX Credit Insurance Insurance Documentation Insurance Flood Insurance Error: Policy number is not provided.                 2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486033   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486033   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486042   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486044   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-01): 4-1-24 APPEAL, providing evidence of Application Date. /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486044   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Missing Unable to test Affiliated Business Disclosure due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486044   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486044   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.     Reviewer Comment (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-01): 4-1-24 APPEAL, providing evidence of Application Date. /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158486044   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.     Reviewer Comment (2024-04-03): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-01): 4-1-24 APPEAL, providing evidence of Application Date. /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158486044   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158486048   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486054   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486054   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-03): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003. There is no alt source for application date in file.


Buyer Comment (2024-04-02): Correction Initial 1003 signed and dated XX/XX/XXXX


Buyer Comment (2024-04-02): Please see Pg 41 to 43 Pg0057 Initial 1003 dated and signed XX/XX/XXXX taken in person states page 4 missing there is nothing on page government monotoring is on page 3.
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX   3158486054   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158486054   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158497262   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497262   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497262   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.     Reviewer Comment (2024-04-03): Exception remains, Missing ARM disclosure from loan file. GFE is referencing Consumer handbook on ARM mortgages.


Buyer Comment (2024-04-02): 4/2/2024: Appeal. Please find GFE (Good Faith Estimate) in Clarity doc # D0029. Just above the borrower's signature, a checked marked that disclosure included ARM loan program disclosure and was acknowledged received by the borrower. LL
        2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158497262   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158497262   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497263   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Investment Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486738   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486738   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486738   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486738   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497266   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497266   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Illegible HUD-1 Used For Fee Testing Material Missing Final HUD-1: Illegible HUD-1 used for any applicable Federal, State or Local compliance testing.     Reviewer Comment (2024-04-09): Regraded to EV2-B.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497266   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497266   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158497266   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158497267   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158497267   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  Estimated HUD-1 Used For Fee Testing Material Missing Final HUD-1:  Estimated HUD-1 used for any applicable Federal, State or Local compliance testing.               3 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   D D D D D     No D
XXXX   3158497267   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used as application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No D
XXXX   3158497267   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No D
XXXX   3158497267   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA 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.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No D
XXXX   3158486067   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486067   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486067   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486067   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486073   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486073   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL itemization did not disclose an Attorney fee of $450 and Title Courier Fee of $25 as prepaid finance charge.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158497272   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497272   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-03): Exception remains. Document noted in appeal is the broker initial loan application. This exception is for the lender initial 1003.


Buyer Comment (2024-04-03): initial 1003


Buyer Comment (2024-04-03): Appeal:  Attached please find the initial 1003 with the loan officer signature and date showing application taken XX/XX/XXXX and signed as final at close on XX/XX/XXXX.
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486084   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486084   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Late Charge New York Late Charge Percent Testing New York Late Charge: Note late charge percent of X.XX% exceeds the state maximum of 2%.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486084   XXXX XXXX XX/XX/XXXX Compliance Compliance State Compliance State Defect New York Prepayment Penalty New York Prepayment Penalty: Maximum prepay term allowed on a loan with an interest rate greater than 6% is 12 months.  Loan with an interest rate of X.XX% contracts for a prepay term of 24 months, which exceeds max allowable.  Prepay language states prepay will not exceed maximum permitted by applicable law.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486086   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486086   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486086   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Flood Certificate Error: Certificate Number was not provided.                 2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486093   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486093   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486093   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. TIL Itemization did not disclose a Settlement/Escrow /Closing $700.00 as prepaid finance charge.             2 XX/XX/XXXX XX 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 TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158486109   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486109   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.     Reviewer Comment (2024-04-17): Exception remains. Per process for alt source for application date, document must state "Application Date" and have lender name to be used.


Buyer Comment (2024-04-16): 4-16-24 APPEAL, Providing evidence of Lender’s initial application disclosure to the borrower.  /dp
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486112   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486112   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158486112   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158486115   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486115   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158486115   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158486115   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497285   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  Missing Signature on Affiliated Business Arrangement Disclosure RESPA Disclosure Rule: Creditor did not obtain signature on Affiliated Business Arrangement Disclosure.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497285   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Under disclosure due to TIL disclosed utilizing an index lower than available within look back. Lowest index within look back is X.XX%.             2 XX/XX/XXXX XX Primary Purchase TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B     Yes B
XXXX   3158497285   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Application Date Alternate source used for application date   At the direction of the client, due to missing the initial application SITUSAMC used an application date systematically produced by the originator for compliance testing.             2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497285   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158486120   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Refinance - Rate/Term No Defined Cure B B B B B     No B
XXXX   3158486125   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C     No B
XXXX   3158486125   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance FACTA FACTA Disclosure Missing FACTA Disclosure Rule: Creditor did not provide FACTA Credit Score Disclosure.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486125   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 0 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B     No B
XXXX   3158486125   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Status Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158486125   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Status TIL variable rate disclosure: Consumer Handbook on Adjustable Rate Mortgages, CHARM Booklet, not provided to the borrower.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX   3158497288   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Prepaid Interest From Date from HUD-1 or final closing disclosure of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497288   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA 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.     Reviewer Comment (2024-04-15): Exception remains, missing aba from application date from loan file.


Buyer Comment (2024-04-11): 04-11-2024  Appeal.  Please see attached Acknowledgment letter signed by the borrower. ABA was mailed on XX/XX/XXXX and application date was XX/XX/XXXX. Trailing docs 11:16 AM.  MC
        2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX   3158497288   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158486139   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test TIL variable rate disclosure: ARM loan program disclosure not provided to the borrower within three (3) days of application.               2 XX/XX/XXXX XX Primary Purchase No Defined Cure B B B B B     No B
XXXX   3158486141   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486141   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application Test No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation. A lookback was performed to determine this application date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486141   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure - Affiliated Business Arrangement Disclosure Not Provided Within 3 Business Days of Application RESPA Disclosure Rule: Unable to determine if Creditor provided Affiliated Business Arrangement Disclosure to applicant within three (3) business days of application due to missing information.     Reviewer Comment (2024-04-18): Letter does not include a copy of the ABA  for review. Exception remains..


Buyer Comment (2024-04-17): Appeal. The loan file contain a letter from Lender  at pg 90/1264 D 0214 that the Disclosure Acknowledgements were mailed see issued date XX/XX/XXXX which should establish ABAD was provided to the customer within 3 days of application.
        2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX   3158486141   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA ARM Disclosure Timing Test Unable to determine if ARM disclosure was provided within three (3) days of application due to missing information.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486141   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA CHARM Booklet Disclosure Timing Unable to determine compliance with timing requirements due to missing Initial Loan Application Date.               2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation No Defined Cure B B B B B     No B
XXXX   3158486141   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form TILA Rescission - Disbursement Date Less than 3 Business Days From Transaction Date Truth in Lending Act:  Subject loan transaction disbursed on XX/XX/XXXX, prior to three (3) business days from transaction date of XX/XX/XXXX 12:00:00 AM.               2 XX/XX/XXXX XX 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 B B B B B     Yes B
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Loan Package Documentation Missing Document: Missing Final 1003       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX UTD UTD - UTD   C C C C C     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Insurance Missing Document: Flood Certificate not provided       Reviewer Comment (2024-04-05): Per client request.
        2 XX/XX/XXXX XX UTD UTD - UTD   C C C C C     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) Initial GFE not provided                 2 XX/XX/XXXX XX UTD UTD - UTD   B B B B B     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Property - Appraisal General Appraisal Requirements LTV Test Due to lack of appraised value, compliance tests requiring an LTV were run off an assumed value of a contract sales price or original loan amount, whichever applies.                 2 XX/XX/XXXX XX UTD UTD - UTD   B B B B B     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Non-Required Data Disbursement Date Missing Test Disbursement Date Missing: Evidence of disbursement date not found in file. Security Instrument Notary Date of XX/XX/XXXX used as disbursement date for compliance testing.               2 XX/XX/XXXX XX UTD UTD - UTD   B B B B B     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete HUD-1 Missing Final HUD-1:  No Document Used For Fee Testing Material Missing Final HUD-1.  No document containing fees provided.  Any applicable Federal, State or Local compliance testing is unreliable.               3 XX/XX/XXXX XX UTD UTD - UTD   D D D D D     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Application Date Missing Initial Loan Application No Fees No evidence of application date located in file.  Compliance tests were run using an application date of XX/XX/XXXX which is 1 months prior to consummation.  A lookback was performed to determine this application date. Due to missing HUD-1 or Closing Disclosure, no fees were used in testing.               2 XX/XX/XXXX XX UTD UTD - UTD   B B B B B     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing Required Data Property Type Not Provided (Missing Data) Property Type. If property type is other than single family residence, state and federal testing may be impacted.     Reviewer Comment (2024-04-17): Exception remains, Unable to determine specific property type at origination.


Buyer Comment (2024-04-17): Appeal. Please see D0859. According to Special Transfer/Assumption Rider to Mortgage subject property satisfy the URA requirement for URA's XXXX Home Ownership Program Single Family Mortgage Revenue Bonds.
        2 XX/XX/XXXX XX UTD UTD - UTD   B B B B B     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Right-to-Cancel Missing, Incorrect, Incomplete and/or provided on the wrong form Notice of Right to Cancel Missing Truth in Lending Act: Notice of Right to Cancel was not provided.               2 XX/XX/XXXX XX UTD UTD - UTD TILA ROR - Provide the following: Letter of Explanation, Proof of Delivery, and Re-open Rescission using the correct model form B B B B B     Yes D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Missing, Incorrect, or Incomplete Final TIL TILA - Final TIL Missing Missing Final TIL.               2 XX/XX/XXXX XX UTD UTD - UTD   B B B B B     No D
XXXX   3158497292   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing Non-Required Data Unable to determine occupancy, compliance results were generated using a defaulted value of Primary.       Reviewer Comment (2024-04-17): Exception remains, Post origination documentation referenced for occupancy, Unable to determine occupancy at origination.


Buyer Comment (2024-04-17): Appeal. Please see D0377 and D0343. Dataverify and XXXX Agent Desktop confirmed property occupancy.
        2 XX/XX/XXXX XX UTD UTD - UTD   B B B B B     No D
XXXX   3158496865   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) - 10% Tolerance Without Cure RESPA (2010): 10% tolerance violation without  evidence of sufficient cure provided. 10% tolerance violation without  evidence of sufficient cure provided.             2 XX/XX/XXXX XX Primary Purchase Provide the following: Letter of Explanation, Proof of Delivery, and Refund check B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496865   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010):  GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges. GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.             2 XX/XX/XXXX XX Primary Purchase   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496865   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) – Written Service Provider List Not Provided Timely RESPA (2010) - Borrower did not receive a list of service providers at the time the Good Faith Estimate was provided. List of service providers was provided on XX/XX/XXXX, not at the time the Good Faith Estimate was provided XX/XX/XXXX.             2 XX/XX/XXXX XX Primary Purchase   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496865   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. Creditor did not provide HUD Settlement Cost Booklet.             2 XX/XX/XXXX XX Primary Purchase   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496866   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet.               2 XX/XX/XXXX XX Primary Purchase   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496866   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010):  GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges. GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.             2 XX/XX/XXXX XX Primary Purchase   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158484873   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX. Final TIL Finance Charge of $XXXX is underdisclosed from calculated Finance Charge of $XXXX in the amount of $XXXX.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term TILA Material Disclosure Cure - Provide the following: Letter of Explanation, Proof of Delivery, Refund check for underdisclosed equivalent amount, Corrected TIL Disclosure, and Re-open Rescission if Applicable B B B B B Safe Harbor QM Safe Harbor QM Yes B
XXXX   3158484873   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance ECOA ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX) Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation.   Reviewer Comment (2024-04-09): Evidence that the Appraisal was provided to the Borrower is missing.


Buyer Comment (2024-04-04): 4/5/2024 Appeal: Please see DOC D0329. The borrower was informed on XX/XX/XXXX that they would receive a copy of any appraisal, even if the loan does not close. CK
        2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Safe Harbor QM Safe Harbor QM No B
XXXX   3158484873   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance ATR/QM Defect QM Employment History - Current and/or Previous Employment Documentation lacks Date Info Qualified Mortgage (Dodd-Frank 2014): Missing Employment Dates to verify two years employment history for current and/or prior employment. (XXXX/XXXX) A copy of the DU findings is missing which caused the loan to test to standard QM requirements.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Safe Harbor QM Safe Harbor QM No B
XXXX   3158484877   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Existence of Escrow Account on Final GFE Inaccurate RESPA (2010): Existence of escrow account disclosed on Final GFE does not match actual terms. Existence of escrow account disclosed on Final GFE does not match actual terms.             2 XX/XX/XXXX XX Primary Purchase   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496879   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance ECOA ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX)               2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496879   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Loan Amount on Final GFE Inaccurate RESPA (2010): Loan Amount on Final GFE does not match Note. The final GFE provided on XX/XX/XXXX disclosed on page 1 an incorrect loan amount and principal and interest loan payment.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496879   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Initial Payment on GFE Inaccurate RESPA (2010): Initial payment on GFE does not match actual payment on loan. The initial GFE provided on XX/XX/XXXX disclosed on page 1 an incorrect loan amount and principal and interest loan payment. No change of circumstance provided to the borrower.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158496880   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance ECOA ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX) A copy of appraisal was not provided three days prior to closing.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B Temporary SHQM (GSE/Agency Eligible) Safe Harbor QM No C
XXXX   3158496880   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance ATR/QM Defect Check Loan Designation Match - QM Qualified Mortgage (Dodd-Frank 2014): Originator Loan Designation of Temporary SHQM (GSE/Agency Eligible) does not match Due Diligence Loan Designation of Safe Harbor QM. Loan is non agency salable causing loan to waterfall to designation of safe harbor QM.             3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other Lender to provide updated ATR/QM status B C B C B Temporary SHQM (GSE/Agency Eligible) Safe Harbor QM Yes C
XXXX   3158496880   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Interest Rate on GFE Inaccurate RESPA (2010): Interest Rate on GFE does not match Note. Interest Rate on GFE X.XX% does not match Note X.XX%.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B Temporary SHQM (GSE/Agency Eligible) Safe Harbor QM No C
XXXX   3158496880   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Initial Payment on GFE Inaccurate RESPA (2010): Initial payment on GFE does not match actual payment on loan. Initial payment on GFE $XXXX does not match actual payment on loan of $XXXX.             2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   B B B B B Temporary SHQM (GSE/Agency Eligible) Safe Harbor QM No C
XXXX   3158496880   XXXX XXXX XX/XX/XXXX Credit Loan Package Documentation Application / Processing Missing Document  Missing Document: AUS not provided   The Zippy findings and 1008 reflect loan was DU approved, but a copy of the DU findings is missing.  The 1008 and Zippy were used for loan review.   Reviewer Comment (2024-04-11): The most recent Zippy shows DU approved XX/XX/XXXX.  The DU findings in the loan file were submitted XX/XX/XXXX and is missing pages.  The final DU submission is required.


Buyer Comment (2024-04-11): 4.11.24 Appeal.  Please see attached the complete Underwriting Approval for this loan which includes, Zippy Approval, DU Approval, 1008, and Underwriting Approval based off Zippy.  All underwriting approval documentation is provided.  Please review and rescind. rk


Reviewer Comment (2024-04-09): The DU findings provided were submitted XX/XX/XXXX.  It appears the final DU submission is missing.  There are Zippy submissions dated XX/XX/XXXX.   Additionally, the DU provided is missing the last page.


Buyer Comment (2024-04-04): 4.4.24 Appeal.  The AUS was provided in the loan file and can be found beginning on page D0733.  Please review and rescind. rk
        3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C Temporary SHQM (GSE/Agency Eligible) Safe Harbor QM No C
XXXX   3158496880   XXXX XXXX XX/XX/XXXX Credit Credit AUS Discrepancy / Guidelines Discrepancy Guideline AUS/Guideline Findings: All conditions were not met   Missing a copy of the DU findings.   Reviewer Comment (2024-04-11): The most recent Zippy shows DU approved XX/XX/XXXX.  The DU findings in the loan file were submitted XX/XX/XXXX and is missing pages.  The final DU submission is required.


Buyer Comment (2024-04-11): 4.11.24 Appeal.  Please see attached the complete Underwriting Approval for this loan which includes, Zippy Approval, DU Approval, 1008, and Underwriting Approval based off Zippy.  All underwriting approval documentation is provided.  Please review and rescind. rk


Reviewer Comment (2024-04-09): The DU findings provided were submitted XX/XX/XXXX.  It appears the final DU submission is missing.  There are Zippy submissions dated XX/XX/XXXX.   Additionally, the DU provided is missing the last page.


Buyer Comment (2024-04-04): 4.4.24 Appeal.  Please specify what conditions were not satisfied in the AUS.  The AUS is already found in the loan file beginning on page D0733.  Please review and rescind. rk
        3 XX/XX/XXXX XX Primary Refinance - Cash-out - Other   C C C C C Temporary SHQM (GSE/Agency Eligible) Safe Harbor QM No C
XXXX   3158496952   XXXX XXXX XX/XX/XXXX Compliance Compliance Miscellaneous Compliance Missing, Incorrect, or Incomplete GFE (Doc Error) GFE Error: Changed Circumstance not provided. GFE Date: XX/XX/XXXX, GFE Date: XX/XX/XXXX, GFE Date: XX/XX/XXXX Changed Circumstance not provided for GFE dated XX/XX/XXXX from GFE dated XX/XX/XXXX
Changed Circumstance not provided for GFE dated XX/XX/XXXX from GFE dated XX/XX/XXXX
Changed Circumstance not provided for GFE dated XX/XX/XXXX from GFE dated XX/XX/XXXX
Changed Circumstance not provided.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Safe Harbor QM Safe Harbor QM No B
XXXX   3158496952   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance ECOA ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX) Creditor did not provide a copy of each valuation to applicant three business days prior to consummation.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Safe Harbor QM Safe Harbor QM No B
XXXX   3158496952   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance ECOA ECOA Appraisal - Copy of Appraisal Not Provided 3 Business Days Prior to Consummation ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide a copy of each valuation to applicant three (3) business days prior to consummation. (Type:Primary/XX/XX/XXXX) A copy of appraisal was not provided three business days prior to closing.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Safe Harbor QM Safe Harbor QM No B
XXXX   3158497036   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance ECOA ECOA Appraisal - Right to Receive Copy of Appraisal Disclosure Not Provided Timely ECOA Valuations Rule (Dodd-Frank 2014): Creditor did not provide "Right to Receive a Copy" appraisal disclosure to applicant within three (3) business days of application or determination of first lien status. Right to Receive a Copy Appraisal is required to be delivered to borrower within 3 business days from application date.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Safe Harbor QM Safe Harbor QM No B
XXXX   3158497037   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance Other TILA Violations TILA NMLSR - Individual Originator License Status Not Approved Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator not licensed to conduct loan origination activities. Individual Loan Originator not licensed to conduct loan origination activities.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158497037   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance TILA TILA NMLSR - Individual Originator NMLS information on documents does not match NMLS website Truth in Lending Act (NMLSR Dodd- Frank 2014): Individual Loan Originator NMLSR information on loan documents does not match NMLSR. Individual Loan Originator NMLSR information on loan documents does not match NMLSR.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) Yes B
XXXX   3158497037   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -   GFE Settlement charges Good Thru Date Less than 10 Days RESPA (2010):  GFE does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges. GFE provided on XX/XX/XXXX does not provide minimum ten (10) business day availability for estimate of charges and terms for all other settlement charges.             2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158497039   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA Disclosure -  HUD Settlement Cost Booklet Missing RESPA Disclosure Rule: Creditor did not provide HUD Settlement Cost Booklet. Creditor did not provide HUD Settlement Cost Booklet.             2 XX/XX/XXXX XX Primary Purchase   B B B B B Safe Harbor QM Safe Harbor QM No B
XXXX   3158497040   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Loan Amount on Final GFE Inaccurate RESPA (2010): Loan Amount on Final GFE does not match Note.               2 XX/XX/XXXX XX Primary Purchase   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B
XXXX   3158497040   XXXX XXXX XX/XX/XXXX Compliance Compliance Federal Compliance RESPA RESPA (2010) -  Initial Payment on GFE Inaccurate RESPA (2010): Initial payment on GFE does not match actual payment on loan.               2 XX/XX/XXXX XX Primary Purchase   B B B B B Temporary SHQM (GSE/Agency Eligible) Temporary SHQM (GSE/Agency Eligible) No B

 

 
 
     
Data Compare      
     
AMC Loan ID Customer Loan ID Alternate Loan ID Seller Loan ID Field Label Bid Tape Field Value Field Value Compare Status
XXXX   3158496239   Street XXXX XXXX Verified
XXXX   3158496239   Property Type XXXX XXXX Verified
XXXX   3158496239   # of Units X X Verified
XXXX   3158496242   Street XXXX XXXX Verified
XXXX   3158482734   Street XXXX XXXX Verified
XXXX   3158482734   # of Units   X Verified
XXXX   3158496250   Borrower First Name XXXX XXXX Verified
XXXX   3158482754   Street XXXX XXXX Verified
XXXX   3158482754   # of Units   X Verified
XXXX   3158496251   Appraised Value $XXXX   Verified
XXXX   3158496251   # of Units   X Verified
XXXX   3158496253   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158482765   Street XXXX XXXX Verified
XXXX   3158482765   City XXXX XXXX Verified
XXXX   3158482765   # of Units   X Verified
XXXX   3158496255   Street XXXX XXXX Verified
XXXX   3158496255   # of Units   X Verified
XXXX   3158482778   Street XXXX XXXX Verified
XXXX   3158482778   Purpose Refinance Purchase Verified
XXXX   3158482778   # of Units   X Verified
XXXX   3158496260   Street XXXX XXXX Verified
XXXX   3158496260   # of Units   X Verified
XXXX   3158482793   Street XXXX XXXX Verified
XXXX   3158482809   Street XXXX XXXX Verified
XXXX   3158482809   City XXXX XXXX Verified
XXXX   3158482809   # of Units   X Verified
XXXX   3158496271   Interest Only 0   Verified
XXXX   3158496271   Appraised Value $XXXX   Verified
XXXX   3158496275   Purpose Refinance Purchase Verified
XXXX   3158496277   Street XXXX XXXX Verified
XXXX   3158496277   Purpose Purchase Refinance Verified
XXXX   3158496277   Appraised Value $XXXX $XXXX Verified
XXXX   3158496279   Street XXXX XXXX Verified
XXXX   3158496279   Zip XXXXX XXXXX Verified
XXXX   3158482850   Street XXXX XXXX Verified
XXXX   3158482859   Borrower First Name XXXX XXXX Verified
XXXX   3158482859   Borrower Last Name XXXX XXXX Verified
XXXX   3158482860   Street XXXX XXXX Verified
XXXX   3158482869   Occupancy Investment Primary Verified
XXXX   3158482875   City XXXX XXXX Verified
XXXX   3158482883   Appraised Value $XXXX   Verified
XXXX   3158482893   Street XXXX XXXX Verified
XXXX   3158482910   Borrower Last Name XXXX XXXX Verified
XXXX   3158482929   Street XXXX XXXX Verified
XXXX   3158482937   City XXXX XXXX Verified
XXXX   3158482942   Borrower Last Name XXXX XXXX Verified
XXXX   3158482945   Zip XXXXX XXXXX Verified
XXXX   3158482945   Property Type XXXX XXXX Verified
XXXX   3158496309   City XXXX XXXX Verified
XXXX   3158496313   Street XXXX XXXX Verified
XXXX   3158496313   City XXXX XXXX Verified
XXXX   3158496313   Appraised Value $XXXX $XXXX Verified
XXXX   3158482967   Street XXXX XXXX Verified
XXXX   3158482968   Interest Only 0 1 Verified
XXXX   3158496324   Street XXXX XXXX Verified
XXXX   3158496324   Appraised Value $XXXX $XXXX Verified
XXXX   3158483003   Street XXXX XXXX Verified
XXXX   3158483013   Street XXXX XXXX Verified
XXXX   3158483013   City XXXX XXXX Verified
XXXX   3158483031   Appraised Value $XXXX   Verified
XXXX   3158483053   Street XXXX XXXX Verified
XXXX   3158483053   City XXXX XXXX Verified
XXXX   3158496347   Street XXXX XXXX Verified
XXXX   3158496347   Property Type XXXX XXXX Verified
XXXX   3158483083   Street XXXX XXXX Verified
XXXX   3158496352   Street XXXX XXXX Verified
XXXX   3158496360   City XXXX XXXX Verified
XXXX   3158496360   Borrower Last Name XXXX XXXX Verified
XXXX   3158483112   Street XXXX XXXX Verified
XXXX   3158483112   Property Type XXXX XXXX Verified
XXXX   3158483112   Interest Only 0 1 Verified
XXXX   3158496364   Street XXXX XXXX Verified
XXXX   3158496364   City XXXX XXXX Verified
XXXX   3158496364   Borrower Last Name XXXX XXXX Verified
XXXX   3158496364   Property Type XXXX XXXX Verified
XXXX   3158483120   Street XXXX XXXX Verified
XXXX   3158483135   City XXXX XXXX Verified
XXXX   3158483135   Property Type XXXX XXXX Verified
XXXX   3158483135   Interest Only 0 1 Verified
XXXX   3158483146   Street XXXX XXXX Verified
XXXX   3158483146   Interest Only 0 1 Verified
XXXX   3158483183   Street XXXX XXXX Verified
XXXX   3158483184   Street XXXX XXXX Verified
XXXX   3158483193   Street XXXX XXXX Verified
XXXX   3158483193   Borrower First Name XXXX XXXX Verified
XXXX   3158496392   Appraised Value $XXXX   Verified
XXXX   3158496396   Borrower First Name XXXX XXXX Verified
XXXX   3158483209   City XXXX XXXX Verified
XXXX   3158483209   Appraised Value $XXXX   Verified
XXXX   3158483210   Street XXXX XXXX Verified
XXXX   3158483210   Property Type XXXX XXXX Verified
XXXX   3158496399   City XXXX XXXX Verified
XXXX   3158496404   Street XXXX XXXX Verified
XXXX   3158496406   Street XXXX XXXX Verified
XXXX   3158483226   Street XXXX XXXX Verified
XXXX   3158483230   Zip XXXXX XXXXX Verified
XXXX   3158483230   Borrower Last Name XXXX XXXX Verified
XXXX   3158483236   Zip XXXXX XXXXX Verified
XXXX   3158483237   Property Type XXXX XXXX Verified
XXXX   3158496410   Property Type XXXX XXXX Verified
XXXX   3158483246   Property Type XXXX XXXX Verified
XXXX   3158483246   # of Units X X Verified
XXXX   3158496413   Appraised Value $XXXX $XXXX Verified
XXXX   3158483272   Zip XXXXX XXXXX Verified
XXXX   3158483283   City XXXX XXXX Verified
XXXX   3158483283   Property Type XXXX XXXX Verified
XXXX   3158496427   Borrower First Name XXXX XXXX Verified
XXXX   3158483287   Street XXXX XXXX Verified
XXXX   3158483319   Property Type XXXX XXXX Verified
XXXX   3158483320   Borrower First Name XXXX XXXX Verified
XXXX   3158483320   Borrower Last Name XXXX XXXX Verified
XXXX   3158483320   # of Units   X Verified
XXXX   3158486308   Street XXXX XXXX Verified
XXXX   3158486308   Interest Only 0 1 Verified
XXXX   3158486308   Appraised Value $XXXX $XXXX Verified
XXXX   3158486308   # of Units X X Verified
XXXX   3158486318   City XXXX XXXX Verified
XXXX   3158496441   Street XXXX XXXX Verified
XXXX   3158496441   City XXXX XXXX Verified
XXXX   3158483350   Street XXXX XXXX Verified
XXXX   3158483350   # of Units   X Verified
XXXX   3158483352   # of Units   X Verified
XXXX   3158483369   Street XXXX XXXX Verified
XXXX   3158483418   Street XXXX XXXX Verified
XXXX   3158483418   Zip XXXXX XXXXX Verified
XXXX   3158483418   Borrower First Name XXXX XXXX Verified
XXXX   3158483418   Property Type XXXX XXXX Verified
XXXX   3158483418   Interest Only 0   Verified
XXXX   3158483418   Appraised Value $XXXX   Verified
XXXX   3158483419   Property Type XXXX XXXX Verified
XXXX   3158483427   Street XXXX XXXX Verified
XXXX   3158483427   Property Type XXXX XXXX Verified
XXXX   3158483427   Interest Only 0   Verified
XXXX   3158483431   Interest Only 0   Verified
XXXX   3158496487   Property Type XXXX XXXX Verified
XXXX   3158496487   Appraised Value $XXXX   Verified
XXXX   3158483507   Property Type XXXX XXXX Verified
XXXX   3158483507   Appraised Value $XXXX   Verified
XXXX   3158483507   # of Units X   Verified
XXXX   3158496496   Interest Only 0   Verified
XXXX   3158496496   Appraised Value $XXXX $XXXX Verified
XXXX   3158483562   Borrower First Name XXXX XXXX Verified
XXXX   3158483562   Interest Only 0   Verified
XXXX   3158483562   Appraised Value $XXXX   Verified
XXXX   3158483563   Property Type XXXX XXXX Verified
XXXX   3158483563   Interest Only 0   Verified
XXXX   3158496508   City XXXX XXXX Verified
XXXX   3158496508   Interest Only 0   Verified
XXXX   3158483572   Interest Only 0   Verified
XXXX   3158483572   Appraised Value $XXXX   Verified
XXXX   3158483587   Interest Only 0   Verified
XXXX   3158483588   Borrower Last Name XXXX XXXX Verified
XXXX   3158483588   Property Type XXXX XXXX Verified
XXXX   3158483588   Occupancy Primary Investment Verified
XXXX   3158483588   Appraised Value $XXXX $XXXX Verified
XXXX   3158496511   Property Type XXXX XXXX Verified
XXXX   3158496511   Interest Only 0   Verified
XXXX   3158483603   Interest Only 0   Verified
XXXX   3158483603   Appraised Value $XXXX   Verified
XXXX   3158483607   Street XXXX XXXX Verified
XXXX   3158483607   Zip XXXXX XXXXX Verified
XXXX   3158483607   Borrower Last Name XXXX XXXX Verified
XXXX   3158483612   Street XXXX XXXX Verified
XXXX   3158483612   Property Type XXXX XXXX Verified
XXXX   3158483612   Interest Only 0   Verified
XXXX   3158483623   Interest Only 0   Verified
XXXX   3158483623   Appraised Value $XXXX   Verified
XXXX   3158483632   Interest Only 0   Verified
XXXX   3158483632   Appraised Value $XXXX   Verified
XXXX   3158496518   Property Type XXXX XXXX Verified
XXXX   3158496518   Interest Only 0   Verified
XXXX   3158496518   Appraised Value $XXXX $XXXX Verified
XXXX   3158496519   Street XXXX XXXX Verified
XXXX   3158496519   Interest Only 0   Verified
XXXX   3158496521   Property Type XXXX XXXX Verified
XXXX   3158496521   Appraised Value $XXXX   Verified
XXXX   3158496521   # of Units X   Verified
XXXX   3158483666   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158496534   Borrower First Name XXXX XXXX Verified
XXXX   3158483676   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158496537   Street XXXX XXXX Verified
XXXX   3158496537   Property Type XXXX XXXX Verified
XXXX   3158496537   Appraised Value $XXXX   Verified
XXXX   3158496537   # of Units X   Verified
XXXX   3158483698   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158483702   Property Type XXXX XXXX Verified
XXXX   3158483702   Appraised Value $XXXX   Verified
XXXX   3158483702   # of Units X   Verified
XXXX   3158483733   Borrower First Name XXXX XXXX Verified
XXXX   3158483765   Street XXXX XXXX Verified
XXXX   3158496561   Property Type XXXX XXXX Verified
XXXX   3158496561   Appraised Value $XXXX   Verified
XXXX   3158483776   Borrower Last Name XXXX XXXX Verified
XXXX   3158483776   Interest Only 0   Verified
XXXX   3158483776   Appraised Value $XXXX   Verified
XXXX   3158483777   Interest Only 0   Verified
XXXX   3158496562   Property Type XXXX XXXX Verified
XXXX   3158496562   Interest Only 0   Verified
XXXX   3158483784   Street XXXX XXXX Verified
XXXX   3158483784   Interest Only 0   Verified
XXXX   3158483806   Interest Only 0   Verified
XXXX   3158483808   Interest Only 0   Verified
XXXX   3158483811   Property Type XXXX XXXX Verified
XXXX   3158483811   Interest Only 0   Verified
XXXX   3158483826   Interest Only 0   Verified
XXXX   3158483859   Property Type XXXX XXXX Verified
XXXX   3158483859   Interest Only 0   Verified
XXXX   3158483859   Appraised Value $XXXX $XXXX Verified
XXXX   3158483868   Interest Only 0   Verified
XXXX   3158483878   Property Type XXXX XXXX Verified
XXXX   3158483883   Street XXXX XXXX Verified
XXXX   3158483883   Borrower First Name XXXX XXXX Verified
XXXX   3158496600   Interest Only 0   Verified
XXXX   3158483894   Zip XXXXX XXXXX Verified
XXXX   3158483894   Property Type XXXX XXXX Verified
XXXX   3158483894   Interest Only 0   Verified
XXXX   3158483912   Interest Only 0   Verified
XXXX   3158496608   Interest Only 0   Verified
XXXX   3158496614   Borrower First Name XXXX XXXX Verified
XXXX   3158496614   Borrower Last Name XXXX XXXX Verified
XXXX   3158496614   Interest Only 0   Verified
XXXX   3158483941   Interest Only 0   Verified
XXXX   3158483941   Appraised Value $XXXX   Verified
XXXX   3158483944   Interest Only 0   Verified
XXXX   3158483944   Appraised Value $XXXX   Verified
XXXX   3158483945   Interest Only 0   Verified
XXXX   3158496616   Interest Only 0   Verified
XXXX   3158496620   Interest Only 0   Verified
XXXX   3158483982   Property Type XXXX XXXX Verified
XXXX   3158483982   Interest Only 0   Verified
XXXX   3158483982   Appraised Value $XXXX $XXXX Verified
XXXX   3158483986   Street XXXX XXXX Verified
XXXX   3158483986   City XXXX XXXX Verified
XXXX   3158483986   Purpose Purchase Refinance Verified
XXXX   3158496621   Street XXXX XXXX Verified
XXXX   3158496621   Interest Only 0   Verified
XXXX   3158483994   Interest Only 0   Verified
XXXX   3158496622   Interest Only 0   Verified
XXXX   3158484010   City XXXX XXXX Verified
XXXX   3158484010   Interest Only 0   Verified
XXXX   3158486368   Street XXXX XXXX Verified
XXXX   3158486368   Interest Only 0   Verified
XXXX   3158496636   Property Type XXXX XXXX Verified
XXXX   3158496636   Interest Only 0   Verified
XXXX   3158496636   Appraised Value $XXXX   Verified
XXXX   3158496636   # of Units X   Verified
XXXX   3158496642   Interest Only 0   Verified
XXXX   3158496644   Interest Only 0   Verified
XXXX   3158496644   Appraised Value $XXXX   Verified
XXXX   3158484091   Interest Only 0   Verified
XXXX   3158484104   Street XXXX XXXX Verified
XXXX   3158484104   Interest Only 0   Verified
XXXX   3158484104   Appraised Value $XXXX   Verified
XXXX   3158496649   Interest Only 0   Verified
XXXX   3158496657   Borrower First Name XXXX XXXX Verified
XXXX   3158496657   Interest Only 0 1 Verified
XXXX   3158496657   Appraised Value $XXXX   Verified
XXXX   3158496658   Street XXXX XXXX Verified
XXXX   3158496658   Appraised Value $XXXX   Verified
XXXX   3158496659   Street XXXX XXXX Verified
XXXX   3158496659   Interest Only 0 1 Verified
XXXX   3158484149   Street XXXX XXXX Verified
XXXX   3158484149   Appraised Value $XXXX $XXXX Verified
XXXX   3158484159   Property Type XXXX XXXX Verified
XXXX   3158484170   Street XXXX XXXX Verified
XXXX   3158484170   Interest Only 0 1 Verified
XXXX   3158484173   Street XXXX XXXX Verified
XXXX   3158496682   Borrower Last Name XXXX XXXX Verified
XXXX   3158484181   Interest Only 0 1 Verified
XXXX   3158484202   Borrower First Name XXXX XXXX Verified
XXXX   3158484202   Borrower Last Name XXXX XXXX Verified
XXXX   3158484202   Interest Only 0   Verified
XXXX   3158484207   Interest Only 0   Verified
XXXX   3158484207   Appraised Value $XXXX   Verified
XXXX   3158484211   Property Type XXXX XXXX Verified
XXXX   3158484211   Interest Only 0   Verified
XXXX   3158484211   Appraised Value $XXXX $XXXX Verified
XXXX   3158496697   Borrower First Name XXXX XXXX Verified
XXXX   3158496697   Occupancy Investment Second Home Verified
XXXX   3158496697   Appraised Value $XXXX   Verified
XXXX   3158484215   Borrower First Name XXXX XXXX Verified
XXXX   3158484215   Interest Only 0   Verified
XXXX   3158484223   Borrower Last Name XXXX XXXX Verified
XXXX   3158484223   Interest Only 0   Verified
XXXX   3158496698   Interest Only 0   Verified
XXXX   3158496698   Appraised Value $XXXX   Verified
XXXX   3158496701   Interest Only 0   Verified
XXXX   3158496701   Appraised Value $XXXX   Verified
XXXX   3158496702   City XXXX XXXX Verified
XXXX   3158496702   Borrower Last Name XXXX XXXX Verified
XXXX   3158496702   Interest Only 0   Verified
XXXX   3158484249   Street XXXX XXXX Verified
XXXX   3158484249   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158484274   Property Type XXXX XXXX Verified
XXXX   3158484274   Interest Only 0 1 Verified
XXXX   3158484274   Appraised Value $XXXX $XXXX Verified
XXXX   3158496713   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158484302   Property Type XXXX XXXX Verified
XXXX   3158484302   Interest Only 0   Verified
XXXX   3158484302   Appraised Value $XXXX   Verified
XXXX   3158484310   Appraised Value $XXXX   Verified
XXXX   3158484315   Interest Only 0   Verified
XXXX   3158484332   Interest Only 0   Verified
XXXX   3158484344   Interest Only 0   Verified
XXXX   3158484352   Interest Only 0   Verified
XXXX   3158496726   Interest Only 0   Verified
XXXX   3158484360   Street XXXX XXXX Verified
XXXX   3158484360   Zip XXXXX XXXXX Verified
XXXX   3158484360   Interest Only 0   Verified
XXXX   3158484365   Interest Only 0   Verified
XXXX   3158496730   Interest Only 0   Verified
XXXX   3158496730   Appraised Value $XXXX   Verified
XXXX   3158496733   Borrower Last Name XXXX XXXX Verified
XXXX   3158496733   Interest Only 0   Verified
XXXX   3158484381   Interest Only 0   Verified
XXXX   3158496738   Interest Only 0   Verified
XXXX   3158496741   Interest Only 0   Verified
XXXX   3158484407   Interest Only 0   Verified
XXXX   3158484419   Interest Only 0   Verified
XXXX   3158484421   Property Type XXXX XXXX Verified
XXXX   3158484421   Interest Only 0   Verified
XXXX   3158484422   Interest Only 0   Verified
XXXX   3158484422   Appraised Value $XXXX   Verified
XXXX   3158484433   First Payment Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158484435   Street XXXX XXXX Verified
XXXX   3158484435   Interest Only 0   Verified
XXXX   3158484444   Property Type XXXX XXXX Verified
XXXX   3158484445   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158484447   Property Type XXXX XXXX Verified
XXXX   3158484469   First Payment Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158496760   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158496760   Appraised Value $XXXX $XXXX Verified
XXXX   3158496760   # of Units   X Verified
XXXX   3158484526   Property Type XXXX XXXX Verified
XXXX   3158484526   Appraised Value $XXXX   Verified
XXXX   3158484526   # of Units X   Verified
XXXX   3158484549   Borrower Last Name XXXX XXXX Verified
XXXX   3158496777   Borrower First Name XXXX XXXX Verified
XXXX   3158496777   Property Type XXXX XXXX Verified
XXXX   3158496777   Appraised Value $XXXX   Verified
XXXX   3158496777   # of Units X   Verified
XXXX   3158484555   Zip XXXXX XXXXX Verified
XXXX   3158484557   Street XXXX XXXX Verified
XXXX   3158484557   Zip XXXXX XXXXX Verified
XXXX   3158484558   Street XXXX XXXX Verified
XXXX   3158484558   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158484558   Property Type XXXX XXXX Verified
XXXX   3158496784   Property Type XXXX XXXX Verified
XXXX   3158484592   City XXXX XXXX Verified
XXXX   3158496793   Street XXXX XXXX Verified
XXXX   3158496793   Borrower Last Name XXXX XXXX Verified
XXXX   3158496794   Borrower First Name XXXX XXXX Verified
XXXX   3158496799   Interest Only 0   Verified
XXXX   3158496801   Interest Only 0   Verified
XXXX   3158484640   Appraised Value $XXXX   Verified
XXXX   3158496802   Borrower First Name XXXX XXXX Verified
XXXX   3158496802   Property Type XXXX XXXX Verified
XXXX   3158496802   Interest Only 0   Verified
XXXX   3158496805   Interest Only 0   Verified
XXXX   3158496808   Appraised Value $XXXX   Verified
XXXX   3158484653   Interest Only 0   Verified
XXXX   3158484654   Interest Only 0   Verified
XXXX   3158484654   Appraised Value $XXXX   Verified
XXXX   3158484655   Street XXXX XXXX Verified
XXXX   3158484655   Interest Only 0   Verified
XXXX   3158484665   Street XXXX XXXX Verified
XXXX   3158484665   Interest Only 0   Verified
XXXX   3158484665   Appraised Value $XXXX   Verified
XXXX   3158484672   Interest Only 0   Verified
XXXX   3158484674   Interest Only 0   Verified
XXXX   3158496811   Interest Only 0   Verified
XXXX   3158496811   Appraised Value $XXXX   Verified
XXXX   3158496812   Borrower First Name XXXX XXXX Verified
XXXX   3158496812   Borrower Last Name XXXX XXXX Verified
XXXX   3158496812   Property Type XXXX XXXX Verified
XXXX   3158496812   Interest Only 0   Verified
XXXX   3158484692   Interest Only 0   Verified
XXXX   3158496818   Interest Only 0   Verified
XXXX   3158484702   Borrower First Name XXXX XXXX Verified
XXXX   3158484702   Interest Only 0   Verified
XXXX   3158484705   Zip XXXXX XXXXX Verified
XXXX   3158484705   Interest Only 0   Verified
XXXX   3158484705   Appraised Value $XXXX   Verified
XXXX   3158484707   Borrower First Name XXXX XXXX Verified
XXXX   3158484707   Property Type XXXX XXXX Verified
XXXX   3158484707   Interest Only 0   Verified
XXXX   3158496822   Interest Only 0   Verified
XXXX   3158496822   Appraised Value $XXXX   Verified
XXXX   3158496825   Interest Only 0   Verified
XXXX   3158496825   Appraised Value $XXXX   Verified
XXXX   3158484722   Property Type XXXX XXXX Verified
XXXX   3158484722   Interest Only 0   Verified
XXXX   3158484734   Property Type XXXX XXXX Verified
XXXX   3158484734   Interest Only 0   Verified
XXXX   3158484761   Borrower Last Name XXXX XXXX Verified
XXXX   3158484761   Property Type XXXX XXXX Verified
XXXX   3158496838   Borrower First Name XXXX XXXX Verified
XXXX   3158496838   Appraised Value $XXXX $XXXX Verified
XXXX   3158484784   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158484784   Property Type XXXX XXXX Verified
XXXX   3158484784   # of Units X X Verified
XXXX   3158484794   Borrower Last Name XXXX XXXX Verified
XXXX   3158484794   Interest Only 0 1 Verified
XXXX   3158484803   Occupancy Primary UTD Verified
XXXX   3158496849   Interest Only 0 1 Verified
XXXX   3158484821   Interest Only 0 1 Verified
XXXX   3158484821   Appraised Value $XXXX $XXXX Verified
XXXX   3158496869   Borrower Last Name XXXX XXXX Verified
XXXX   3158496869   Appraised Value $XXXX $XXXX Verified
XXXX   3158496881   Appraised Value $XXXX   Verified
XXXX   3158496884   Street XXXX XXXX Verified
XXXX   3158496887   Interest Only 0 1 Verified
XXXX   3158484902   Street XXXX XXXX Verified
XXXX   3158484902   Interest Only 0 1 Verified
XXXX   3158484915   Street XXXX XXXX Verified
XXXX   3158484915   Interest Only 0 1 Verified
XXXX   3158496893   Street XXXX XXXX Verified
XXXX   3158496893   Interest Only 0 1 Verified
XXXX   3158496895   Street XXXX XXXX Verified
XXXX   3158496898   Occupancy Second Home Primary Verified
XXXX   3158484932   Street XXXX XXXX Verified
XXXX   3158484932   Interest Only 0 1 Verified
XXXX   3158496907   Zip XXXXX XXXXX Verified
XXXX   3158496911   Zip XXXXX XXXXX Verified
XXXX   3158496911   Borrower Last Name XXXX XXXX Verified
XXXX   3158496919   Property Type XXXX XXXX Verified
XXXX   3158496919   Interest Only 0 1 Verified
XXXX   3158496920   Interest Only 0 1 Verified
XXXX   3158496920   Appraised Value $XXXX $XXXX Verified
XXXX   3158496922   Property Type XXXX XXXX Verified
XXXX   3158496922   Interest Only 0 1 Verified
XXXX   3158486528   Street XXXX XXXX Verified
XXXX   3158486528   Appraised Value $XXXX $XXXX Verified
XXXX   3158496937   Street XXXX XXXX Verified
XXXX   3158496937   Borrower First Name XXXX XXXX Verified
XXXX   3158496937   Borrower Last Name XXXX XXXX Verified
XXXX   3158496937   Property Type XXXX XXXX Verified
XXXX   3158485008   Street XXXX XXXX Verified
XXXX   3158485008   Interest Only 0 1 Verified
XXXX   3158485025   Interest Only 0 1 Verified
XXXX   3158485028   Property Type XXXX XXXX Verified
XXXX   3158485028   Appraised Value $XXXX   Verified
XXXX   3158485028   # of Units X   Verified
XXXX   3158485034   Interest Only 0 1 Verified
XXXX   3158485059   Street XXXX XXXX Verified
XXXX   3158485059   Interest Only 0 1 Verified
XXXX   3158485059   Appraised Value $XXXX $XXXX Verified
XXXX   3158496954   Street XXXX XXXX Verified
XXXX   3158496954   Interest Only 0 1 Verified
XXXX   3158496955   Street XXXX XXXX Verified
XXXX   3158496955   Interest Only 0 1 Verified
XXXX   3158496958   Street XXXX XXXX Verified
XXXX   3158496958   City XXXX XXXX Verified
XXXX   3158496958   Property Type XXXX XXXX Verified
XXXX   3158496962   Interest Only 0 1 Verified
XXXX   3158496964   Street XXXX XXXX Verified
XXXX   3158496966   Street XXXX XXXX Verified
XXXX   3158496972   Street XXXX XXXX Verified
XXXX   3158485109   Street XXXX XXXX Verified
XXXX   3158496977   Street XXXX XXXX Verified
XXXX   3158485116   Appraised Value $XXXX $XXXX Verified
XXXX   3158496984   Interest Only 0 1 Verified
XXXX   3158496987   Interest Only 0 1 Verified
XXXX   3158485139   Street XXXX XXXX Verified
XXXX   3158485149   Property Type XXXX XXXX Verified
XXXX   3158485149   Interest Only 0 1 Verified
XXXX   3158497002   Street XXXX XXXX Verified
XXXX   3158497002   Borrower First Name XXXX XXXX Verified
XXXX   3158497002   Borrower Last Name XXXX XXXX Verified
XXXX   3158485162   Street XXXX XXXX Verified
XXXX   3158485162   Zip XXXXX XXXXX Verified
XXXX   3158497006   Street XXXX XXXX Verified
XXXX   3158497006   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158485177   Borrower Last Name XXXX XXXX Verified
XXXX   3158485177   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158485194   Street XXXX XXXX Verified
XXXX   3158485226   Street XXXX XXXX Verified
XXXX   3158485226   Interest Only 0 1 Verified
XXXX   3158497056   Appraised Value $XXXX $XXXX Verified
XXXX   3158497061   Street XXXX XXXX Verified
XXXX   3158497061   Appraised Value $XXXX   Verified
XXXX   3158497066   Street XXXX XXXX Verified
XXXX   3158497066   Property Type XXXX XXXX Verified
XXXX   3158497072   Street XXXX XXXX Verified
XXXX   3158497072   # of Units X X Verified
XXXX   3158497074   Borrower First Name XXXX XXXX Verified
XXXX   3158497074   Borrower Last Name XXXX XXXX Verified
XXXX   3158485298   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158485318   Street XXXX XXXX Verified
XXXX   3158485318   Zip XXXXX XXXXX Verified
XXXX   3158485321   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158485321   Appraised Value $XXXX $XXXX Verified
XXXX   3158497093   Borrower Last Name XXXX XXXX Verified
XXXX   3158497098   Purpose Purchase Refinance Verified
XXXX   3158485343   Street XXXX XXXX Verified
XXXX   3158485349   Appraised Value $XXXX $XXXX Verified
XXXX   3158486608   City XXXX XXXX Verified
XXXX   3158485363   Street XXXX XXXX Verified
XXXX   3158485363   Property Type XXXX XXXX Verified
XXXX   3158485363   Appraised Value $XXXX $XXXX Verified
XXXX   3158486638   Property Type XXXX XXXX Verified
XXXX   3158486638   Interest Only 0 1 Verified
XXXX   3158497115   Street XXXX XXXX Verified
XXXX   3158497115   Borrower First Name XXXX XXXX Verified
XXXX   3158497115   Borrower Last Name XXXX XXXX Verified
XXXX   3158485374   Interest Only 0   Verified
XXXX   3158485380   Property Type XXXX XXXX Verified
XXXX   3158485380   Interest Only 0   Verified
XXXX   3158485384   Borrower Last Name XXXX XXXX Verified
XXXX   3158485384   Property Type XXXX XXXX Verified
XXXX   3158485384   Interest Only 0   Verified
XXXX   3158485384   Appraised Value $XXXX $XXXX Verified
XXXX   3158485390   Borrower Last Name XXXX XXXX Verified
XXXX   3158485390   Property Type XXXX XXXX Verified
XXXX   3158485390   Interest Only 0   Verified
XXXX   3158485407   Interest Only 0   Verified
XXXX   3158485409   Interest Only 0   Verified
XXXX   3158485431   Interest Only 1   Verified
XXXX   3158485441   Interest Only 0   Verified
XXXX   3158497130   Interest Only 0   Verified
XXXX   3158485447   Borrower First Name XXXX XXXX Verified
XXXX   3158485447   Borrower Last Name XXXX XXXX Verified
XXXX   3158497132   Interest Only 0   Verified
XXXX   3158485454   Interest Only 0 1 Verified
XXXX   3158485454   Appraised Value $XXXX   Verified
XXXX   3158485484   Property Type XXXX XXXX Verified
XXXX   3158497146   Interest Only 0   Verified
XXXX   3158497148   Property Type XXXX XXXX Verified
XXXX   3158497148   Interest Only 0   Verified
XXXX   3158485535   Street XXXX XXXX Verified
XXXX   3158485535   Interest Only 0 1 Verified
XXXX   3158485555   City XXXX XXXX Verified
XXXX   3158485555   Interest Only 0   Verified
XXXX   3158485560   Borrower Last Name XXXX XXXX Verified
XXXX   3158485560   Interest Only 0 1 Verified
XXXX   3158497165   Interest Only 0   Verified
XXXX   3158497170   Interest Only 0   Verified
XXXX   3158485604   Interest Only 0   Verified
XXXX   3158485608   Interest Only 0 1 Verified
XXXX   3158497178   City XXXX XXXX Verified
XXXX   3158497178   Interest Only 0   Verified
XXXX   3158485625   Interest Only 0   Verified
XXXX   3158485627   Property Type XXXX XXXX Verified
XXXX   3158485627   Interest Only 0   Verified
XXXX   3158497182   Interest Only 0   Verified
XXXX   3158497182   Appraised Value $XXXX $XXXX Verified
XXXX   3158486648   Street XXXX XXXX Verified
XXXX   3158485641   Property Type XXXX XXXX Verified
XXXX   3158485641   Appraised Value $XXXX $XXXX Verified
XXXX   3158497184   Interest Only 0   Verified
XXXX   3158497186   Interest Only 0   Verified
XXXX   3158485653   City XXXX XXXX Verified
XXXX   3158485653   Borrower Last Name XXXX XXXX Verified
XXXX   3158485657   Interest Only 0   Verified
XXXX   3158485659   Interest Only 0 1 Verified
XXXX   3158485665   Interest Only 0 1 Verified
XXXX   3158485675   Interest Only 0 1 Verified
XXXX   3158497198   Interest Only 0 1 Verified
XXXX   3158497198   Appraised Value $XXXX   Verified
XXXX   3158485680   Interest Only 0 1 Verified
XXXX   3158485683   Interest Only 0   Verified
XXXX   3158497205   Street XXXX XXXX Verified
XXXX   3158497205   Interest Only 0   Verified
XXXX   3158485708   Property Type XXXX XXXX Verified
XXXX   3158485708   Interest Only 0   Verified
XXXX   3158485713   Street XXXX XXXX Verified
XXXX   3158485713   Interest Only 0 1 Verified
XXXX   3158485713   Appraised Value $XXXX   Verified
XXXX   3158485728   Interest Only 0 1 Verified
XXXX   3158485728   Appraised Value $XXXX   Verified
XXXX   3158485775   Interest Only 0   Verified
XXXX   3158485786   Street XXXX XXXX Verified
XXXX   3158485786   Property Type XXXX XXXX Verified
XXXX   3158497218   Street XXXX XXXX Verified
XXXX   3158497218   Property Type XXXX XXXX Verified
XXXX   3158485821   Interest Only 0   Verified
XXXX   3158485825   Interest Only 0   Verified
XXXX   3158497225   Interest Only 0   Verified
XXXX   3158485836   Property Type XXXX XXXX Verified
XXXX   3158485836   Interest Only 0   Verified
XXXX   3158485842   Zip XXXXX XXXXX Verified
XXXX   3158485842   Property Type XXXX XXXX Verified
XXXX   3158485842   Interest Only 0   Verified
XXXX   3158485871   Interest Only 0   Verified
XXXX   3158485871   Appraised Value $XXXX   Verified
XXXX   3158486718   Street XXXX XXXX Verified
XXXX   3158486718   City XXXX XXXX Verified
XXXX   3158486718   Borrower Last Name XXXX XXXX Verified
XXXX   3158486718   Interest Only 0   Verified
XXXX   3158485874   Interest Only 0   Verified
XXXX   3158485874   Appraised Value $XXXX $XXXX Verified
XXXX   3158485885   Interest Only 0   Verified
XXXX   3158485887   Interest Only 0   Verified
XXXX   3158485898   Property Type XXXX XXXX Verified
XXXX   3158497247   Interest Only 0 1 Verified
XXXX   3158497247   Appraised Value $XXXX $XXXX Verified
XXXX   3158486014   Street XXXX XXXX Verified
XXXX   3158486014   Interest Only 0   Verified
XXXX   3158486021   Interest Only 0   Verified
XXXX   3158497255   Street XXXX XXXX Verified
XXXX   3158497255   Property Type XXXX XXXX Verified
XXXX   3158497255   Interest Only 0 1 Verified
XXXX   3158486033   Interest Only 0   Verified
XXXX   3158486042   Street XXXX XXXX Verified
XXXX   3158486042   Interest Only 0   Verified
XXXX   3158486044   Street XXXX XXXX Verified
XXXX   3158486044   Property Type XXXX XXXX Verified
XXXX   3158486044   Interest Only 0   Verified
XXXX   3158486048   Street XXXX XXXX Verified
XXXX   3158486048   Property Type XXXX XXXX Verified
XXXX   3158486054   Interest Only 0   Verified
XXXX   3158497262   Property Type XXXX XXXX Verified
XXXX   3158497262   Interest Only 0 1 Verified
XXXX   3158497263   Street XXXX XXXX Verified
XXXX   3158497263   Interest Only 0 1 Verified
XXXX   3158497266   Property Type XXXX XXXX Verified
XXXX   3158497266   Interest Only 0 1 Verified
XXXX   3158497266   Appraised Value $XXXX $XXXX Verified
XXXX   3158497267   Interest Only 0   Verified
XXXX   3158486067   Interest Only 0 1 Verified
XXXX   3158486073   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158486073   Original Loan Amount $XXXX $XXXX Verified
XXXX   3158486073   First Payment Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158486073   Property Type XXXX XXXX Verified
XXXX   3158497272   Borrower First Name XXXX XXXX Verified
XXXX   3158497272   Appraised Value $XXXX $XXXX Verified
XXXX   3158486086   Street XXXX XXXX Verified
XXXX   3158486086   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158486086   Purpose Purchase Refinance Verified
XXXX   3158486093   Note Date XX/XX/XXXX XX/XX/XXXX Verified
XXXX   3158486093   Property Type XXXX XXXX Verified
XXXX   3158486093   Purpose Purchase Refinance Verified
XXXX   3158486093   # of Units X X Verified
XXXX   3158486112   Purpose Purchase Refinance Verified
XXXX   3158486115   Appraised Value $XXXX   Verified
XXXX   3158497285   Borrower First Name XXXX XXXX Verified
XXXX   3158497285   Property Type XXXX XXXX Verified
XXXX   3158497285   Interest Only 0   Verified
XXXX   3158486120   Street XXXX XXXX Verified
XXXX   3158486120   Property Type XXXX XXXX Verified
XXXX   3158486120   Interest Only 0   Verified
XXXX   3158486125   Street XXXX XXXX Verified
XXXX   3158486125   Interest Only 0   Verified
XXXX   3158497288   Property Type XXXX XXXX Verified
XXXX   3158497288   Interest Only 0   Verified
XXXX   3158497288   Appraised Value $XXXX   Verified
XXXX   3158486139   Property Type XXXX XXXX Verified
XXXX   3158486139   Interest Only 0   Verified
XXXX   3158486141   Zip XXXXX XXXXX Verified
XXXX   3158486141   Interest Only 0   Verified
XXXX   3158497292   Street XXXX XXXX Verified
XXXX   3158497292   City XXXX XXXX Verified
XXXX   3158497292   Occupancy Primary UTD Verified
XXXX   3158497292   Purpose Purchase UTD Verified
XXXX   3158496866   Street XXXX XXXX Verified
XXXX   3158497038   Street XXXX XXXX Verified
XXXX   3158497040   Property Type XXXX XXXX Verified