ACHM Trust 2024-HE1 April 10, 2024 Due Diligence Narrative Report

TABLE OF CONTENTS ACHM Trust 2024‐HE1 Page | 1 April 10, 2024 Clayton Contact Information ......................................................................................................................................................... 2 Overview ...................................................................................................................................................................................... 2 Originators .................................................................................................................................................................................... 2 Clayton’s Third Party Review (‘TPR’) Scope of Work ....................................................................................................................... 2 Sampling ................................................................................................................................................................................................ 3 Sponsor Acquisition Criteria ................................................................................................................................................................... 3 Loan Grading.......................................................................................................................................................................................... 3 TPR Component Review Scope ............................................................................................................................................................... 4 Credit Review ..................................................................................................................................................................................... 4 Property Valuation Review ................................................................................................................................................................ 5 Regulatory Compliance Review ......................................................................................................................................................... 5 Data Integrity ......................................................................................................................................................................................... 6 Data Capture.......................................................................................................................................................................................... 6 Data Compare Results ................................................................................................................................................................... 7 Clayton Due Diligence Results........................................................................................................................................................ 8 Clayton Third Party Reports Delivered ........................................................................................................................................... 9

CLAYTON CONTACT INFORMATION Client Service Management: Chris Turk Client Service Manager Phone: (813) 472-6509/E-mail: Cturk@clayton.com Joe Ozment Director of Securitization Phone: (813) 261-0733/E-mail: jozment@clayton.com OVERVIEW On behalf of Achieve Home Loans, Clayton conducted an independent third‐party pre‐securitization due diligence review of HELOC residential loans selected for the ACHM Trust 2024‐HE1 transaction. At the request of Achieve, Clayton chose a random sample of 823 loans for a Full Review scope. A Full Review scope review encompasses a Credit, Valuation and Compliance review as described under the ‘TPR Component Review Scope’ section of this narrative. Clayton performed a Compliance Only review on an additional 893 loans. The Compliance Review scope is described under the ‘TPR Component Review Scope’ of this Narrative Report. The loans referenced in this narrative report were reviewed on a bulk basis in July 2022 – March 2024 at Clayton’s centralized underwriting facilities in Tampa, FL. This narrative report provides information about the original lenders, the scope of work performed by Clayton, and the results of Clayton’s review. ORIGINATORS Origination channels for the loans in this review: Origination Channel Loan Count Percentage Retail 1,716 100.00% Total 1,716 100.00% CLAYTON’S THIRD PARTY REVIEW (‘TPR’) SCOPE OF WORK The scope of work for this transaction consisted of credit, property valuation, and regulatory compliance reviews, plus a data integrity check, were performed in accordance with rating agency1 loan level review standards in place as of the date of the review. This is referred to as a ‘Full Review.’ 1 Standard and Poor’s, Moody’s, Fitch, Kroll, DBRS & Morningstar ACHM Trust 2024‐HE1 Page | 2 April 10, 2024

SAMPLING Diligence provider periodically receives asset tapes listing all loans originated by Achieve in a specified period and randomly selects loans from those asset tapes for review. For the ACHM Trust 2024‐HE1 transaction, 823 loans received a Full Review, and 893 loans received a Compliance Only Review. The scope of each Full Review and Compliance Only Review are described below. Review Type Loan Counts: Review Type Loan Count Reviewed by Clayton Scope Applied Full Review 823 Clayton performed a Full Review based on the scope described below in the section titled ‘TPR Component Review Scope’. Compliance Only 893 Clayton performed a Compliance Only Review based on the scope Review described below in the section titled ‘TPR Component Review Scope’ Total Loan 1,716 Population SPONSOR ACQUISITION CRITERIA The loans were originated to Lendage’s guidelines and Clayton reviewed the 823 loans selected for a full scope review to the guideline requirements listed below, (‘Sponsor Acquisition Criteria’). Clayton was supplied with all the changes to the guidelines. Primary Guideline Lendage/HELOC UW Policy v1/09/2021 Lendage/HELOC UW Policy v2/09/2021 Lendage/HELOC UW Policy v3/10/2021 Lendage/HELOC UW Policy v4/11/2021 Lendage/HELOC UW Policy v5/06/2022 Lendage/HELOC UW Policy V6/09/2022 Lendage/HELOC UW Policy V7/04/2023 Lendage/HELOC UW Policy V9/04/2023 LOAN GRADING Each loan received an ‘initial’ and a ‘final’ grade. The ‘initial’ grade was assigned during the initial loan review. The ‘final’ grade takes into account additional information and supporting documentation that may have been provided by the originators to clear outstanding conditions. Clayton is providing a comprehensive loan‐level analysis as part of this pre‐securitization reporting ACHM Trust 2024‐HE1 Page | 3 April 10, 2024

package that includes initial grades, final grades and detailed commentary on the rationale for any changes in grades and sets forth waivers. The compliance exception report lists all exceptions within a loan. Clayton’s loan grading complied with the following rating agency grading definitions published by Moody’s, Standard and Poor’s, Fitch, Kroll and DBRS: TPR COMPONENT REVIEW SCOPE Clayton examined the selected loan files with respect to the presence or absence of relevant documents, enforceability of mortgage loan documents, and accuracy and completeness of data fields. Clayton relied on the accuracy of information contained in loan documentation provided to Clayton. CREDIT REVIEW The credit review for HELOCs will include: Compare the loan documentation found in the loan file to the origination guidelines; Re‐calculate LTV, CLTV, income, liabilities, and debt‐to‐income ratios (DTI) and compare these against the stated origination guidelines; Analyze asset statements in order to determine that funds to close and reserves were within origination guidelines; Confirm that credit scores (FICO) and credit histories were within origination guidelines; Evaluate for evidence of borrower’s willingness and ability to repay the obligation; Examine income, employment, assets, and occupancy status for reasonability; Review the occupancy, VOE and/or self‐employed business documents within the loan file, as applicable; Review gift funds for adherence to origination guidelines; Review property type for adherence to origination guidelines; Review Preliminary Title/Title Commitment for Lien Position, Vesting, Lender Coverage Amount and any material defects; Verify presence of Mortgage/Deed of Trust and execution by all parties with all riders and addendums; Verify whether the borrower obtained and meets the minimum required amount of hazard and flood coverage required by the guidelines, as indicated by the applicable insurance declarations page; List compensating factors based on the loan file and Client guidelines; and Verify presence of the HELOC Agreement and execution by all parties. ACHM Trust 2024‐HE1 Page | 4 April 10, 2024

PROPERTY VALUATION REVIEW Clayton’s Property Valuation scope of review conducted on this transaction included the following elements: Value Supported Analysis Clayton applied a cascade methodology to determine if the original AVM value was reasonably supported when compared to another AVM from a different provider. For loans reviewed in a post‐close valuation review scenario: On 699 Loans an Automated Valuation Model (‘AVM’) was ordered by Clayton to show support of value. On 118 loans, a 2nd valuation product was ordered. On 70 of these loans, supported value was shown. On 6 loans, a Broker Price Opinion (BPO) was ordered by Clayton. On 4 loans, supported value was shown. On 28 loans, supported value was not able to be shown. If a loan with an AVM fell outside of a ‐10% tolerance or was inconclusive, then a 2nd AVM was completed. 118 loans fell outside of tolerance. If a loan with a 2nd AVM fell outside of a ‐10% tolerance or was inconclusive, then a BPO was completed. REGULATORY COMPLIANCE REVIEW Clayton’s Regulatory Compliance scope of review conducted on this transaction included the elements summarized below. Clayton utilized its proprietary eCLAS engine for regulatory compliance testing. The HELOC Regulatory Compliance Review will include: ROR testing (form type and closing of rescission) TILA APR tolerance testing on the final HELOC disclosure (Tolerance is 0.125%) For application date prior to 10/3/2015: Fee tolerance testing between Early Disclosure and final HELOC disclosure (Tolerance is $100) If a HUD is used, comparison of fees on HUD to fees disclosed on the final HELOC disclosure. ACHM Trust 2024‐HE1 Page | 5 April 10, 2024 For loans with an application date on or after January 10, 2014, the HELOC Regulatory Compliance Review testing includes HOEPA testing. State high cost and/or higher‐priced testing is done for the following state, county, and municipal laws: Arkansas High Cost Chicago High Cost Cleveland Heights High Cost Colorado High Cost Cook County High Cost Connecticut High Cost

District of Columbia High Cost Florida High Cost Georgia High Cost Illinois High Cost Maine High Cost Maryland High Cost Massachusetts High Cost and Subprime ARMS to 1st Time Homebuyers Minnesota Subprime PPP restriction New Jersey High Cost New Mexico High Cost North Carolina High Cost Ohio High Cost Pennsylvania High Cost Rhode Island High Cost Utah High Cost DATA INTEGRITY Clayton utilized its proprietary eCLAS tool to determine tape to file accuracy of each reviewed loan, by completing the following steps: Tape data received from lender/client is stored in eCLAS; Loan Reviewer collects validated loan data in eCLAS; Each received data point is compared to its counterpart collected data point; Discrepancies found during comparison are stored. DATA CAPTURE ACHM Trust 2024‐HE1 Page | 6 April 10, 2024

Clayton collected data fields required to create the American Securitization Forum (‘ASF’) data disclosure requirements. The file format is provided as part of the pre‐securitization reporting package. DATA COMPARE RESULTS Clayton provided Achieve with a copy of the Loan Level Tape Compare Upload which shows the differences between the data received by the sellers versus the data captured by Clayton during the loan review. Summary of data compare results: ACHM Trust 2024‐HE1 Page | 7 April 10, 2024 Field Name # Accuracy % Borrower 1 Self Employed Flag 3 99.83% Combined LTV 19 98.89% Debt to Income Ratio (Back) 68 96.04% Disbursement Date 1 99.94% First Payment Date 1 99.94% Lien Position 12 99.30% Original Appraisal Date 6 99.65% Original LTV 1 99.94% Property Type 7 99.59% Representative Credit Score for Grading 2 99.88%

CLAYTON DUE DILIGENCE RESULTS Below are the initial and final overall loan grades for this review, as well as the credit, property valuation, and regulatory compliance component review grades. Initial and Final Overall Loan Grade Results Loan Pool (1,716 loans) ACHM Trust 2024‐HE1 Page | 8 April 10, 2024 Overall Grade Migration Initial Final A B C D Total A 1,547 7 93 17 1,664 B 10 4 4 18 C 29 2 31 D 3 3 Total 1,547 17 126 26 1,716 The overall grade summary reflects the combination of the credit, property valuation and regulatory compliance component reviews into one overall grade. The overall grade assigned is the most severe grade from each of the component reviews. Initial and Final Credit Component Grade Results Credit Grade Migration Initial Final A B C D Total A 777 4 20 15 816 B 1 2 3 C 1 1 D 3 3 Total 777 5 22 19 823 Initial and Final Property Valuation Grade Results Property Valuation Grade Migration Initial Final A B C D Total A 715 3 74 792 B 1 1 C 30 30 D 0 Total 715 3 105 0 823 Initial and Final Regulatory Compliance Grade Results Compliance Grade Migration Initial Final A B C D Total A 1,694 5 3 1,702 B 10 4 14 C 0 D 0 Total 1,694 10 5 7 1,716

CLAYTON THIRD PARTY REPORTS DELIVERED Clayton furnished the following reports on this transaction: Narrative Report Conditions Report ASF Report ATR QM Upload Rating Agency ATR QM Data Fields Loan Level Tape Compare Upload Valuations Summary Report Waived Conditions Summary DBRS Attestation © 2024 Clayton Services LLC. All rights reserved. This material is confidential and may not be copied, used, or distributed without the written permission of Clayton Services LLC. ACHM Trust 2024‐HE1 Page | 9 April 10, 2024