EX-99.29 30 ex99-29.htm DIGITAL RISK REBUTTAL FINDINGS REPORT
 

CSMC 2022-NQM5 Trust ABS-15G

 

Exhibit 99.29

 

Loan Number Loan ID Finding # Last Name Note Date Audit Category Audit Issue Finding ID Exception Finding Remediation Status Exception Rebuttal Exception Response Status Comment Initial Findings Grade Final Findings Grade Initial Loan Grade Final Loan Grade
XXXX 436296044 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296044 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296044 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 436296046 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296046 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296046 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 436296048 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296048 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296048 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The File contains a CDA which supports the opinion of value in the origination report.         1 1 1 1
XXXX 436296049 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 436296049 2 of 3 XXXX XX/XX/XXXX Credit Appraisal - Other XXXX The Appraisal provided is not completely legible; pages are cut off at top and bottom. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXPM)
Appraisal attached.

 Response 1 (XX/XX/XXXX XX:XXPM)
Documentation received is sufficient. (Resolved)

   3 1 3 1
XXXX 436296049 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The File contains a CDA which supports the opinion of value in the origination report.         1 1 3 1
XXXX 437325288 1 of 4 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 437325288 2 of 4 XXXX XX/XX/XXXX Credit Hazard Insurance - Missing/Insufficient XXXX The loan was missing current hazard insurance policy on the subject property with sufficient coverage/replacement cost. The lender guidelines require rent loss coverage if the property is vacant. The hazard policy does not reflect rent loss coverage. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXAM)
The guidelines say that the hazard insurance policy may exclude rent loss when the property is vacant. Document attached.

 Response 1 (XX/XX/XXXX XX:XXPM)
Documentation received is sufficient. (Resolved)

   3 1 3 1
XXXX 437325288 3 of 4 XXXX XX/XX/XXXX Credit Program Parameters - Loan Amount XXXX The loan amount exceeds maximum allowable under the guidelines. The lender guidelines state that if the borrower owned the subject property for less than 12 months, the loan amount will be limited to 100% of the acquisition cost plus the costs of documented improvements. According to the appraisal in the loan file, the subject property was purchased by the borrower on XX/XX/XXXX for XXXX. The loan-to-value was based on the appraised value of XXXX and loan amount of XXXX; however, the loan file did not contain documentation supporting the improvements and the increase in value as required. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXAM)
Improvements attached.

 Response 1 (XX/XX/XXXX XX:XXPM)
Documentation received is sufficient. (Resolved)

   3 1 3 1
XXXX 437325288 4 of 4 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA that supports the opinion of value in the origination appraisal report.         1 1 3 1
XXXX 436296055 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296055 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296055 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 436296057 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296057 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296057 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 436296058 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296058 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296058 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The File contains a CDA which supports the opinion of value in the origination report.         1 1 1 1
XXXX 436296059 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296059 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296059 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 437325289 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 437325289 2 of 3 XXXX XX/XX/XXXX Credit Income - Rental Property Income XXXX The documentation supporting income real estate owned is not adequately supported to meet underwriting guidelines. Missing XXXX results used to justify monthly rental amount. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXAM)
Document attached.

 Response 1 (XX/XX/XXXX XX:XXPM)
Documentation received is sufficient. (Resolved)

   3 1 3 1
XXXX 437325289 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CDA in file supports the appraised value.         1 1 3 1
XXXX 436296062 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296062 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296062 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The file contains a CDA which supports the opinion of value in the origination report.         1 1 1 1
XXXX 436296064 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296064 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296064 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 437325290 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 437325290 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 437325290 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 436296066 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296066 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296066 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CDA in file supports the appraised value.         1 1 1 1
XXXX 436296067 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436296067 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436296067 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 437325291 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 437325291 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 437325291 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 437325292 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 437325292 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 437325292 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The File contains a CDA which supports the opinion of value in the origination report.         1 1 1 1
XXXX 437325293 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 437325293 2 of 3 XXXX XX/XX/XXXX Credit Verification Documentation - VOE Self-Employed/Missing XXXX Guidelines indicate underwriter to re-verify the entity’s good standing status directly through the Secretary of State. The proof of good standing will expire simultaneously with the underwriting approval expiration, or within 30 days, whichever is greater. The file contains the business search verified through XXXX website; however, the date the document was obtained is not reflected. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXPM)
Documentation uploaded.

 Response 1 (XX/XX/XXXX XX:XXPM)
Documentation received is sufficient. (Resolved)

   3 1 3 1
XXXX 437325293 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The File contains a CDA which supports the opinion of value in the origination report.         1 1 3 1
XXXX 437325295 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 437325295 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 437325295 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The File contains a CDA which supports the opinion of value in the origination report.         1 1 1 1
XXXX 437325298 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 437325298 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 437325298 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 437325301 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 437325301 2 of 3 XXXX XX/XX/XXXX Credit Program Parameters - Loan Amount XXXX The loan amount exceeds maximum allowable under the guidelines. The lender guidelines state that if the borrower owned the subject property for less than 12 months, the loan amount will be limited to 100% of the acquisition cost plus the costs of documented improvements. According to the appraisal in the loan file, the subject property was purchased by the borrower on XX/XX/XXXX for XXXX. The loan-to-value was based on the appraised value of XXXX and loan amount of XXXX; however, the loan file did not contain documentation supporting the improvements and the increase in value as required. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXAM)
Loan amount was less than purchased price, so within the 100%.

 Response 1 (XX/XX/XXXX XX:XXPM)
Explanation received is sufficient. (Resolved)

   3 1 3 1
XXXX 437325301 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA that supports the opinion of value in the origination appraisal report.         1 1 3 1
XXXX 437325302 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 437325302 2 of 3 XXXX XX/XX/XXXX Credit Appraisal - Other XXXX There are additional appraisal findings. Appraisal is incomplete, missing information at top and bottom of pages due to incomplete imaging. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXAM)
Appraisal attached.

 Response 1 (XX/XX/XXXX XX:XXPM)
Documentation received is sufficient. (Resolved)

   3 1 3 1
XXXX 437325302 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CDA in file supports the appraised value.         1 1 3 1
XXXX 437325303 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 437325303 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 437325303 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a CDA which supports the opinion of value in the origination appraisal report.         1 1 1 1
XXXX 434315058 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 434315058 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 434315058 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is not supported within 10% of original appraisal amount XXXX The loan file did not contain a CDA, Field Review, or 2nd Appraisal to support the origination appraised value. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXAM)
VRA attached

 Response 1 (XX/XX/XXXX XX:XXPM)
Documentation received is sufficient. (Resolved)

   1 1 1 1
XXXX 434315059 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 434315059 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 3 1
XXXX 434315059 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is not supported within 10% of original appraisal amount XXXX The loan file did not contain a CDA, Field Review, or 2nd Appraisal to support the origination appraised value. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXAM)
Executive approval guideline exception attached

Rebuttal 2 (XX/XX/XXXX XX:XXAM)
Client responded. VRA provided.

 Response 1 (XX/XX/XXXX XX:XXAM)
Exception granted by Investor. (Resolved)

Response 2 (XX/XX/XXXX XX:XXAM)
VRA provided and supports original appraised value. (Resolved)

   3 1 3 1
XXXX 434950719 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 434950719 2 of 3 XXXX XX/XX/XXXX Credit Appraisal - Other XXXX There are additional appraisal findings. Subject appraisal completed XX/XX/XXXX, FEMA Individual Assistance was authorized for (XXXXXX) on XX/XX/XXXX for subject XXXX County. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXPM)
Property Inspection report attached

 Response 1 (XX/XX/XXXX XX:XXAM)
Documentation received is sufficient to clear the exception. (Resolved)

   3 1 3 1
XXXX 434950719 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is not supported within 10% of original appraisal amount XXXX The loan file did not contain a CDA, Field Review, or 2nd Appraisal to support the origination appraised value. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXPM)
Loan originated under guidelines 2021_09v2 which state that for a 5-8 MF or 2-8 MU only one appraisal is required

 Response 1 (XX/XX/XXXX XX:XXAM)
Documentation received is not sufficient to clear the exception. A VRA is required for all 5-8 MF and all mixed use properties. (Upheld)

Response 2 (XX/XX/XXXX XX:XXPM)
Documentation received is sufficient. (Resolved)

   3 1 3 1
XXXX 435050670 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 3 1
XXXX 435050670 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 3 1
XXXX 435050670 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is not supported within 10% of original appraisal amount XXXX The loan file did not contain a CDA, Field Review, or 2nd Appraisal to support the origination appraised value. Resolved Rebuttal 1 (XX/XX/XXXX XX:XXPM)
Loan originated under guidelines 2021_09v2 which state that for a 5-8 MF or 2-8 MU only one appraisal is required

Rebuttal 2 (XX/XX/XXXX XX:XXAM)
VRA uploaded.

 Response 1 (XX/XX/XXXX XX:XXAM)
A VRA secondary valuation product is required for the subject property type. (Upheld)

Response 2 (XX/XX/XXXX XX:XXAM)
Documentation received is sufficient. (Resolved)

   3 1 3 1
XXXX 436021069 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436021069 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436021069 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. CDA in file supports the appraised value.         1 1 1 1
XXXX 436082670 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 1
XXXX 436082670 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 1
XXXX 436082670 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is supported within 10% of original appraisal amount XXXX The appraised value was supported within 10% and all applicable appraisal guidelines were satisfied. The loan file contains a VRA which supports the value in the origination appraisal report.         1 1 1 1
XXXX 436082671 1 of 3 XXXX XX/XX/XXXX Compliance No Compliance Findings XXXX The loan is in compliance with all applicable laws and regulations.         1 1 1 2
XXXX 436082671 2 of 3 XXXX XX/XX/XXXX Credit No Credit Findings XXXX The loan meets all applicable credit guidelines.         1 1 1 2
XXXX 436082671 3 of 3 XXXX XX/XX/XXXX Valuation Appraisal - Value is not supported within 10% of original appraisal amount XXXX Subject contains a VRA which did not support value in origination appraisal report within 10%. However; VRA value was used for LTV calculation for subject transaction therefore a EV2 grading is required.         2 2 1 2