EX-99.1 3 ex99-1s2.htm SCHEDULE 2 - COMPLIANCE REPORT

 

J.P. MORGAN RESIDENTIAL MORTGAGE ACCEPTANCE CORP. ABS-15G

 Exhibit 99.1 - Schedule 2

 

 

 

Grade Summary
 
Standard and Poor's Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 0 0 0 0
B 0 13 0 13
C 0 0 0 0
D 0 0 0 0
N/A 0 0 0 0
Total 0 13 0 13
         
FiXXh Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 0 0 0 0
B 0 13 0 13
C 0 0 0 0
D 0 0 0 0
N/A 0 0 0 0
Total 0 13 0 13
         
DBRS Rating Agency Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 0 0 0 0
B 0 13 0 13
C 0 0 0 0
D 0 0 0 0
N/A 0 0 0 0
Total 0 13 0 13
         
Moodys Rating Agency Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 0 0 0 0
B 0 13 0 13
C 0 0 0 0
D 0 0 0 0
N/A 0 0 0 0
Total 0 13 0 13
         
Kroll Rating Agency Loan Grades
Final Loan Grade Credit Compliance Property Overall
A 0 0 0 0
B 0 13 0 13
C 0 0 0 0
D 0 0 0 0
Total 0 13 0 13

 

 

  

 

 

Loan Level Exception - Disposition

AMC Loan ID Customer Loan ID Seller Loan ID Alternate 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 FiXXh Final Rating Moodys Final Rating DBRS Final Rating SP Final Rating Kroll Final Rating
XXXX     3158537169 XXXXX $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] 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] 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.  The final date used for testing was XX/XX/XXXX.
[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 $XXX is underdisclosed from calculated Finance Charge of $XXX in the amount of $4,888.24.		 Federal Compliance - Final TIL Finance Charge Under Disclosed: It appears the lender used an index lower than XX%, which is the lowest rate in the look back period.  Unable to identify which is correct index due to missing source document.   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.		     - B B B B B
XXXX     3158537178 XXXXX $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     3158537351 XXXXX $XXX XX XX/XX/XXXX Primary Refinance Rate/Term   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 $XXX is underdisclosed from calculated Finance Charge of $XXX in the amount of $257.36.		 Federal Compliance - Final TIL Finance Charge Under Disclosed: Unable to determine reason for under disclosure due to missing itemization of prepaid finance charges. REVIEWER - GENERAL COMMENT (2022-10-02): No alternative source of lender application date located in file.
BUYER - GENERAL COMMENT (2022-10-21): 10.21.22 Appeal attached initial application signed dated XX/XX/XXXX mortgage broker contract dated signed XX/XX/XXXX (GFE initial disclosures inFile dated XX/XX/XXXX) FINAL application dated signed XX/XX/XXXX stamped FINAL.Note date XX/XX/XXXX kindly rescind EV1 XX.
REVIEWER - GENERAL COMMENT (2022-10-24): Exception remains, documents provided are broker initial documents. Missing Lenders initial documents.
BUYER - GENERAL COMMENT (2022-10-21): 10.21.22 Appeal attached 2 different TIL with itemization description of settlement charges, 2 different good faith estimated dated application date and signed XX/XX/XXXX Note date XX/XX/XXXX kindly rescind EV1.XX.
REVIEWER - GENERAL COMMENT (2022-10-24): Exception remains, TIL utilized is borrower signed. Missing itemization of amount financed from loan file of disclosed TIL.
BUYER - GENERAL COMMENT (2022-10-27): 10.27.22 Appeal 2nd- please review description of settlement charges submitted, Note date XX/XX/XXXX for this timeline, document supported kindly EV1.XX.
REVIEWER - GENERAL COMMENT (2022-11-01): Unable to locate itemization for TIL at time of closing in images provided. Exception remains.		 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     3158537035 XXXXX $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] 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 (2022-10-12): XX/XX/XXXXppeal : Please refer to CHARM booklet disclosure provided in Trailing docs on XX/XX/XXXXhich also confirms receipt of the ARM disclosure. XX
REVIEWER - GENERAL COMMENT (2022-10-12): Correct date was captured, Unable to confirm compliance due to 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     - B B B B B
XXXX     3158536822 XXXXX $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     3158537314 XXXXX $XXX XX XX/XX/XXXX Primary Purchase   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     3158536850 XXXXX $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] State Compliance - California APLS Broker Compensation: Lender paid yield spread premiums (YSP) were not included in the California APLS points and fees.
[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 $XXX is underdisclosed from calculated Finance Charge of $XXX in the amount of $782.30.		 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 (2024-01-24): Please provide the legal reference for this citation.
REVIEWER - GENERAL COMMENT (2024-01-29): We cite the EV2-B due to the overall ambiguity in the law prior toXX/XX/XXXX as well as the lack of assignee liability.  However, the intent of the exception is to point out that if the YSP was included in the CA points and fees total, the points and fees would exceed 6% and there would be a high cost violation.  A future purchaser may have a different interpretation of the CA law where YSP is included. As such, this exception should remain an EV-2 B for visibility of the potential risk. Please note the client can waive this EV2-B exception.		 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     3158537691 XXXXX $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 $250,000 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 - 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 $XXX is underdisclosed from calculated Finance Charge of $XXX in the amount of $350.00.		 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 processing fee of $200.00, service charges $65.00, Title closer fee of $395.00 and  Courier fee of $50.00 as prepaid finance charge.

TIL Itemization only disclosed an attorney fee in the amount of $1250.00 and final HUD reflects $950.00 and courier fee of $40.00 and HUD reflects $30.00.		   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     3158536862 XXXXX $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 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 $XX is underdisclosed from calculated Finance Charge of $XX in the amount of $269.75.		 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     3158536987 XXXXX $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     3158537100 XXXXX $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 $XX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($XX).  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 $XX is underdisclosed from calculated Finance Charge of $XX in the amount of $230.37.		 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     3158537356 XXXXX $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     3158540439 XXXXX $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

 

 

  

 

 

 

Exception Ratings

AMC Loan ID Customer Loan ID Seller Loan ID Alternate 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 FiXXh 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     3158537169 12570773   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.  The final date used for testing was XX/XX/XXXX.               2 XX/XX/XXXX XX Primary Purchase   B B B B B     No B
XXXX     3158537169 12570575   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 Purchase   B B B B B     No B
XXXX     3158537169 12618800   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     3158537169 12570778   XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from calculated Finance Charge of $XXX in the amount of $4,888.24. It appears the lender used an index lower than XX%, which is the lowest rate in the look back period.  Unable to identify which is correct index due to missing source document.             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     3158537169 12570774   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     3158537169 12570775   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     3158537178 26910917   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     3158537351 26863803   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 (2022-10-24): Exception remains, documents provided are broker initial documents. Missing Lenders initial documents.


Buyer Comment (2022-10-21): 10.21.22 Appeal attached initial application signed dated XX/XX/XXXX mortgage broker contract dated signed XX/XX/XXXX (GFE initial disclosures inFile dated XX/XX/XXXX) FINAL application dated signed XX/XX/XXXX stamped FINAL.Note date XX/XX/XXXX kindly rescind EV1 XX.


Reviewer Comment (2022-10-02): No alternative source of lender application date located in file.
         2 XX/XX/XXXX XX Primary Refinance - Rate/Term   B B B B B     No B
XXXX     3158537351 26863805   XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from calculated Finance Charge of $XXX in the amount of $257.36. Unable to determine reason for under disclosure due to missing itemization of prepaid finance charges.   Reviewer Comment (2022-11-01): Unable to locate itemization for TIL at time of closing in images provided. Exception remains.


Buyer Comment (2022-10-27): 10.27.22 Appeal 2nd- please review description of settlement charges submitted, Note date XX/XX/XXXX for this timeline, document supported kindly EV1.XX.


Reviewer Comment (2022-10-24): Exception remains, TIL utilized is borrower signed. Missing itemization of amount financed from loan file of disclosed TIL.


Buyer Comment (2022-10-21): 10.21.22 Appeal attached 2 different TIL with itemization description of settlement charges, 2 different good faith estimated dated application date and signed XX/XX/XXXX Note date XX/XX/XXXX kindly rescind EV1.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     3158537035 26865017   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     3158537035 26865018   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 (2022-10-12): Correct date was captured, Unable to confirm compliance due to missing lender initial application date. Exception remains.


Buyer Comment (2022-10-12): XX/XX/XXXXppeal : Please refer to CHARM booklet disclosure provided in Trailing docs on XX/XX/XXXXhich also confirms receipt of the ARM disclosure. XX
         2 XX/XX/XXXX XX Primary Refinance - Cash-out - Other No Defined Cure B B B B B     No B
XXXX     3158537035 26865066   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     3158536822 28395990   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     3158537314 28390908   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     3158536850 29717082   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     3158536850 29717175   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     3158536850 29717176   XX/XX/XXXX Compliance Compliance State Compliance State Compliant California APLS Broker Compensation Lender paid yield spread premiums (YSP) were not included in the California APLS points and fees.     Reviewer Comment (2024-01-29): We cite the EV2-B due to the overall ambiguity in the law prior toXX/XX/XXXX as well as the lack of assignee liability.  However, the intent of the exception is to point out that if the YSP was included in the CA points and fees total, the points and fees would exceed 6% and there would be a high cost violation.  A future purchaser may have a different interpretation of the CA law where YSP is included. As such, this exception should remain an EV-2 B for visibility of the potential risk. Please note the client can waive this EV2-B exception.


Buyer Comment (2024-01-24): Please provide the legal reference for this citation.
         2 XX/XX/XXXX XX Primary Refinance - Cash-out - Debt Consolidation   B B B B B     No B
XXXX     3158536850 29717177   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     3158536850 29731383   XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from calculated Finance Charge of $XXX in the amount of $782.30. 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     3158537691 29728216   XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XXX is underdisclosed from calculated Finance Charge of $XXX in the amount of $350.00. TIL itemization did not disclose processing fee of $200.00, service charges $65.00, Title closer fee of $395.00 and  Courier fee of $50.00 as prepaid finance charge.

TIL Itemization only disclosed an attorney fee in the amount of $1250.00 and final HUD reflects $950.00 and courier fee of $40.00 and HUD reflects $30.00.		             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     3158537691 29728214   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     3158537691 29728170   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     3158537691 29728215   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 $250,000 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     3158536862 30265536   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     3158536862 30265635   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     3158536862 30265637   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 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     3158536862 30265638   XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XX is underdisclosed from calculated Finance Charge of $XX in the amount of $269.75. 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     3158536987 30267767   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     3158536987 30267769   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     3158537100 30268653   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     3158537100 30292364   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     3158537100 30268657   XX/XX/XXXX Compliance Compliance Federal Compliance TILA Final TIL Finance Charge Under Disclosed Truth In Lending Act: Final TIL Finance Charge of $XX is underdisclosed from calculated Finance Charge of $XX in the amount of $230.37. 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     3158537100 30268655   XX/XX/XXXX Compliance Compliance State Compliance State Defect Michigan Prepayment Penalty Michigan Prepayment Penalty: Maximum calculated prepay of $XX exceeds the state maximum for first lien loans of 1% of the prepaid balance ($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     3158537100 30268654   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     3158537100 30268652   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     3158537100 30268651   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     3158537356 30269275   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     3158537356 30269365   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     3158540439 30274839   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     3158540439 30274840   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     3158540439 30274842   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     3158540439 30274843   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     3158540439 30274845   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     3158540439 30274846   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

 

 

  

 

 

Data Compare

 

AMC Loan ID Customer Loan ID Seller Loan ID Alternate Loan ID Field Label Bid Tape Field Value Field Value Compare Status
XXXX     3158537169 Original Interest Rate XX  XX  Verified
XXXX     3158537169 Original P&I XXXX XXXX Verified
XXXX     3158537169 Borrower Full Name XXXX XXXX Ignored
XXXX     3158537178 Original Interest Rate XX  XX  Verified
XXXX     3158537351 Coborrower Last Name XXXX XXXX Verified
XXXX     3158537351 Original Interest Rate XX  XX  Verified
XXXX     3158537035 Original Interest Rate XX  XX  Verified
XXXX     3158537314 Borrower Last Name XXXX XXXX Verified
XXXX     3158537314 Property Type Mobile Home Manufactured Housing Verified
XXXX     3158537314 Borrower First Name XXXX XXXX Verified
XXXX     3158536850 Original P&I XXXX XXXX Verified
XXXX     3158536850 Original Interest Rate XX  XX  Verified
XXXX     3158536850 Refi Purpose Rate/Term Cash-out - Debt Consolidation Verified
XXXX     3158537691 Refi Purpose Rate/Term Cash-out - Debt Consolidation Verified
XXXX     3158537691 Interest Only 0   Verified
XXXX     3158537100 Borrower First Name XXXX XXXX Verified
XXXX     3158537100 Borrower Last Name XXXX XXXX Verified
XXXX     3158537100 Interest Only 0   Verified
XXXX     3158537356 Street XXXX XXXX Verified
XXXX     3158540439 Interest Only 0   Verified