EX-99.3 9 efc19-622_ex993s1.htm SCHEDULE 1 - COMPLIANCE SUMMARY
AMC Unique LOAN ID Compliance Event Compliance Exceptions Compliance Comments Eligible For Predatory Testing - Unable to Test Compliance Comp Factors Category S&P Compliance Grade Fitch Compliance Grade Moody's Compliance Grade DBRS Compliance Grade
70007913 2 [2] Initial TIL Missing [2] Initial GFE Missing [2] Credit Score Disclosure Not Present         RB B B B
70010375 2 [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial TIL Missing         RB B B B
70030663 2 [2] State - Missing Anti-Coercion Notice [2] State - Missing Pre-Application Dislcosure [2] Initial GFE Missing         RB B B B
70039371 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
70053789 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Affiliated Business Doc Missing [2] State - Missing Attorney/Insurance Preference Dislcosure [2] State - Missing Agency to Receive Borrower Complaints [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
70054226 3 [3] ROR Missing [3] Finance Charge underdisclosed >$35 for Refinance [2] State - Missing Disclosure of Terms of Mortgage Application [2] State - Missing Appraisal Notice [2] Initial GFE Missing [2] Initial TIL Missing Finance charges under disclosed by $54.69 which exceeds the $35 tolerance for refinance transactions. Unable to determine under disclosure due to missing itemization of amount financed.   ROR - 3yrs for rescindable transactions. The loan is outside the SOL. Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
70070898 2 [2] Affiliated Business Doc Missing [2] State - Missing Acknowledgment of Receipt of Home Mortgage Loan Informational Document / Attorney General Information Statement [2] State - Missing Mortgage Loan Origination Dislcosure [2] State - Missing Attorney General Information Statement [2] State - Missing Statutory Authority Disclosure [2] State - Missing Closing Statement / Closing Disclosure [2] Initial GFE Missing         RB B B B
70193352 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
70209085 2 [2] Initial GFE Missing         RB B B B
70268502 3 [3] Violation of TX Equity Out 12 Day Cooling-Off Period [3] [TXH] Home Loan Provision: No evidence found that TX 50(a)(6) loan is reviewed by a Texas attorney prior to closing [2] State - Missing Notice of Penalties for Making False or Misleading Written Statement [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Affiliated Business Doc Missing [TXH] Home Loan Provision: No evidence found that TX 50(a)(6) loan is reviewed by a Texas attorney prior to closing [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure in file was executed on 02/XX/2007 and subject loan closed 04/XX/2007; however, lender did not received borrower's application until 04/XX/2007 violating the TX Equity Out 12 day cooling-off period.   A 50a6 violation may lead to forfeiture of all principal and interest. A 50a6 violation may lead to forfeiture of all principal and interest. State - NC RC C C C
70321087 2 [2] Affiliated Business Doc Missing         RB B B B
70338729 2 [2] State - Missing Waiver of Borrower's Rights [2] State - Missing Affidavit of Borrower Under Residential Mortgage Act [2] State - Missing GA Foreclosure Disclosure / Notice Pursuant To O.C.G.A. Section 7-1 [2] State - Missing Right to Select Attorney Disclosure [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
70417643 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
70420603 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Mising Illinois Mortgage Escrow Act Disclosure [2] State - Missing Escrow Account Disclosure Agreement [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
70460357 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure         RB B B B
70504456 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
70557460 2 [2] State - Missing Non Agency Disclosure [2] State - Missing Notice of Right to Discontinue Escrow [2] State - Missing Right to Choose Insurance Provider [2] Initial GFE Incomplete [2] Initial TIL Missing Incomplete initial GFE due to missing date.       RB B B B
70590600 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
70615141 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Pre-Application Dislcosure [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
70631630 2 [2] State - Missing Anti-Coercion Notice [2] State - Missing Choice of Attorney disclosure [2] State - Missing Amortization Information Disclosure         RB B B B
70683867 2 [2] State - Missing Guarantee Of Loan Program [2] State - Missing MD Mandatory Arbitration Disclosure [2] State - Missing MD No Escrow Account Disclosure [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Disclosure of Seller-Paid Fees [2] State - Missing Mortgage Broker Agreement [2] State - Missing Written Acknowledgement of Delivery of the Note [2] State - Missing Credit Grantor Election [2] State - Missing MD Notice of Housing Counseling and Services disclosure         RB B B B
70688385 2 [2] State - Missing signed Notice of Mortgage Broker Fee [2] Initial GFE Missing         RB B B B
70712598 2 [2] Initial GFE Missing         RB B B B
70862322 3 [3] HUD-1 Missing [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Credit Score Disclosure Not Present [2] State - Missing Borrower Information Document [2] State - Missing Rate and Points Lock/Float Agreement [2] State - Missing Description of Underwriting Criteria and Required Documentation [2] State - Missing Commitment Letter [2] Initial GFE Missing   YES TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TR Indeterminable RD D D D
70951561 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Credit Score Disclosure Not Present [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
70971668 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Application Addedum stating applicant, if married, may apply for a separate account [2] State - Missing Consumer Credit Score Disclosure [2] State - Missing Fair Lending Notice [2] State - Missing Hazard Insurance Disclosure [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Impound Authorization Disclosure [2] State - Missing Interim Interest Disclosure [2] State - Missing Home Equity Loan Disclosure [2] State - Missing Waiver of Title Insurance Disclosure [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
70973150 1           RA A A A
70978945 3 [3] TIL Missing [2] Credit Score Disclosure Not Present [2] State - Missing Notice to Purchaser-Mortgagor [2] State - Missing Anti-Coercion Notice   NO   TNR Testing Not Required RB B B B
71019533 3 [3] [GA] Home Loan Provision: Mandatory Arbitration Provision found in file. GA Fair Lending Act as amended by Senate Bill 53 prohibits mandatory arbitration clause on GA home loans. [2] Affiliated Business Doc Missing [2] State - Missing Commitment Disclosure [2] State - Missing Right to Select Attorney Disclosure [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [GA] Home Loan Provision: Mandatory Arbitration Provision found in file. GA Fair Lending Act as amended by Senate Bill 53 prohibits mandatory arbitration clause on GA home loans.     State - NC RC C C C
71109958 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial GFE Date not within 3 days of Initial Application Date [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Waiver of Borrower's Rights [2] State - Missing Affidavit of Borrower Under Residential Mortgage Act [2] State - Missing GA Foreclosure Disclosure / Notice Pursuant To O.C.G.A. Section 7-1 [2] State - Missing Right to Select Attorney Disclosure [2] Initial TIL Missing         RB B B B
71202067 2 [2] Affiliated Business Doc Missing [2] State - Missing Attorneys' Fees Disclosure [2] State - Missing Wet Settlement / Delivery of Net Proceeds Authorization [2] State - Missing Written Acknowledgement of Delivery of the Note         RB B B B
71204781 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Notice to Purchaser-Mortgagor [2] State - Missing Pre-Application Dislcosure [2] Initial TIL Missing         RB B B B
71224633 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Rate Lock Disclosure [2] State - Missing Disclosure of Facts Material to the Borrower's Decision, Rights or Interests [2] State - Missing Disclosure of Loans that Borrower Qualifies For [2] State - Missing Mortgage Loan Summary [2] Initial TIL Missing         RB B B B
71237100 1           RA A A A
71471654 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
71498137 3 [3] ROR Missing [2] State - Missing Rate and Points Lock/Float Agreement [2] HMDA-reportable rate spread (1/1/04-10/1/09)     ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA SOL Expired RB B B B
71507667 3 [3] Finance Charge underdisclosed >$35 for Refinance [2] Affiliated Business Doc Missing [2] State - Missing Anti-Coercion Notice [2] State - Missing Choice of Attorney disclosure Finance charges under disclosed by $85 which exceeds the $35 tolerance for refinance transactions. TIL itemization did not disclose a courier fee of $60 as a prepaid finance charge.   Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
71509436 2 [2] Credit Score Disclosure Not Present         RB B B B
71517906 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
71521453 2 [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RB B B B
71569188 3 [3] HELOC Underdislosed Finance Charge Finance charges under disclosured by $200. The initial fee disclosure did not disclosure a Closing Fee of $250.   1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability.The loan is outside the SOL. TILA SOL Expired RB B B B
71661346 3 [3] TIL Missing [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Mortgage Consumer Disclosure [2] State - Missing Commitment Letter [2] State - Missing Rate Lock [2] State - Missing Application Disclosure [2] State - Missing Freedom to Choose / Anti-Coercion Disclosure [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)   NO   TNR Testing Not Required RB B B B
71717871 2 [2] Credit Score Disclosure Not Present [2] State - Missing Right to Select Attorney Disclosure [2] Initial TIL Missing         RB B B B
71800663 1           RA A A A
71819444 3 [3] APR Tolerance UnderDisclosed 0.125 [3] Finance Charge underdisclosed >$100 for Purchase [3] Federal Higher-Priced Mortgage Loan [2] HMDA-reportable rate spread (10/1/09 and later) [2] State - Missing Complaints and Inquiries Notice APR under disclosed by .4689 which exceeds the .125 tolerance. Federal Higher-Priced Mortgage Loan - Audited APR (5.5939%) exceeds the HPML threshold of 5.23% (1.5% over applicable APOR, 3.73%). Loan appears to comply with repayment ability, prepayment penalty, and escrow restrictions and requirements applicable to Federal HPMLs. Finance charges under disclosed by $2609.29 which exceeds the $100 for purchase. TIL Itemization did not disclose settlement fees: Origination fee $1547.33, discount points $547.75 final inspection fee $75.00, Bond commitment fee $560 and wire fee $10 as prepaid finance charges.   APR - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. Federal Higher-Priced Mortgage Loan - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. FHPML - Compliant RB B B B
71901267 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RB B B B
71964855 1           RA A A A
72040022 1           RA A A A
72128099 2 [2] State - Missing Credit Agreeement/Rate Lock [2] State - Missing Guaranty Terms Agreement [2] State - Missing Dual Status / Dual Capacity Disclosure [2] State - Missing required broker disclosure [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Right to Choose Insurance Provider [2] State - Missing Tangible Net Benefit Disclosure         RB B B B
72215088 1           RA A A A
72301638 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] State - Missing Anti-Coercion Notice [2] State - Missing Disclosure of Terms of Mortgage Application [2] State - Missing NMLS Unique Identifier # and WA CLA mortgage loan originator's license number on the application [2] State - Missing Oral Agreement Notice [2] State - Missing Notice of Right to Cancel Private Mortgage Insurance         RB B B B
72378291 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Affiliated Business Doc Missing [2] State - Missing Broker Agreement [2] State - Mising Illinois Mortgage Escrow Act Disclosure [2] State - Missing Rate and Points Lock/Float Agreement [2] State - Missing Description of Underwriting Criteria and Required Documentation [2] State - Missing Loan Product Choice / Prepayment Penalty Disclosure [2] State - Missing Escrow Account Disclosure Agreement [2] State - Missing Collateral Protection Act Disclosure [2] State - Missing Commitment Letter [2] State - Missing Notice of Choice of Agent or Insurer [2] State - Missing Loan Brokerage Disclosure Statement [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
72528607 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Property Tax Benefit Disclosure (State Form 51781 (6-04) [2] Initial TIL Missing         RB B B B
72530616 2 [2] Credit Score Disclosure Not Present [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RB B B B
72747064 2 [2] State - Missing Lock In Agreement [2] State - Missing Mortgage Loan Commitment [2] Initial GFE Missing         RB B B B
72774171 3 [3] Finance Charge underdisclosed >$35 for Refinance [2] Affiliated Business Doc Missing [2] State - Missing Commitment Letter [2] State - Missing Rate Lock [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09) Finance charges under disclosed by $299.82 which exceeds the $35 tolerance for refinance transactions. Unable to determine under disclosure due to missing itemization of amount financed.   Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
72812501 3 [3] TIL Missing [3] ROR Missing [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Anti-Coercion Notice [2] State - Missing Choice of Attorney disclosure [2] State - Missing Amortization Information Disclosure [2] State - Missing Fee Information From Your Mortgage Broker For Your Mortgage Loan [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TR TIL Deficiency RB B B B
72833314 2 [2] Credit Score Disclosure Not Present [2] Initial TIL Missing         RB B B B
72895080 2 [2] State - Missing MD Balloon Disclosure         RB B B B
72988469 2 [2] State - Missing Appraisal Notice         RB B B B
73083900 3 [3] ROR Missing [2] Credit Score Disclosure Not Present [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure     ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA SOL Expired RB B B B
73089324 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
73145768 3 [3] HUD-1 Estimated [2] State - Missing Notice to Purchaser-Mortgagor [2] State - Missing Pre-Application Dislcosure [2] State - Missing Notice of Material Change of Mortgage Loan Terms [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date Estimated HUD in file is executed by the borrower and certified by the settlement agent. NO   TNR Testing Not Required RD D D D
73179579 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Affiliated Business Doc Missing [2] State - Missing Fair Lending Notice [2] State - Missing Hazard Insurance Disclosure [2] State - Missing Mortgage Broker Agreement [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Domestic Partnership Affidavit [2] State - Missing Impound Authorization Disclosure [2] State - Missing Interim Interest Disclosure [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
73234240 2 [2] Initial GFE Date not within 3 days of Initial Application Date [2] State - Missing Comparison of Sample Mortgage Features: Typical Mortgage [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial TIL Missing         RB B B B
73258869 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
73280578 2 [2] State - Missing Rate and Points Lock/Float Agreement [2] State - Missing Application Disclosure Statement [2] State - Missing Description of Underwriting Criteria and Required Documentation [2] State - Missing Collateral Protection Act Disclosure [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
73328262 3 [3] TIL Missing [3] ROR Missing [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] State - Missing Notice to Mortgage Applicants / Legal Representation Notice [2] Initial GFE Missing [2] Initial TIL Missing   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TR Indeterminable RD D D D
73420480 3 [3] TIL Missing [3] ROR Missing [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Application Disclosure [2] State - Missing Mortgage Broker Agreement [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TR TIL Deficiency RB B B B
73527909 1           RA A A A
73544390 2 [2] Credit Score Disclosure Not Present [2] State - Missing Broker Agreement [2] State - Missing Freedom to Choose Insurance Provider disclosure [2] State - Missing Notice to Borrower/Prospective Borrower / Homeowner Protection Notice [2] State - Missing Property Tax Benefit Disclosure (State Form 51781 (6-04)         RB B B B
73553226 2 [2] State - Missing Commitment Letter [2] State - Missing Consumer Disclosure Statement [2] State - Missing Application Disclosure [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial TIL Missing         RB B B B
73636149 2 [2] State - Missing Attorney Disclosure [2] State - Missing Insurance Disclosure [2] State - Missing Mortgage Broker Agreement [2] State - Missing Initial Tax Authorization Notice [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RB B B B
73818849 2 [2] Initial TIL Missing         RB B B B
73830155 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date         RB B B B
73849532 3 [3] ROR Missing [3] HUD-1 Incomplete [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] State - Missing Adjustable Rate Loan Without Prepayment Penalty [2] Initial GFE Missing Final HUD not executed by the borrower or certified by the settlement agent. Final HUD is also missing page 2 of the HUD cut-off, all fees were not captured. NO ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TNR Testing Not Required RD D D D
73868787 2 [2] State - Missing Disclosure of Terms of Mortgage Application [2] State - Missing Lock In Disclosure [2] State - Missing Virginia Insurance Disclosure [2] State - Missing signed Notice of Mortgage Broker Fee [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
73913359 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
73918046 3 [3] [TXH] Home Loan Provision: No evidence found that TX 50(a)(6) loan is reviewed by a Texas attorney prior to closing [2] State - Missing Notice of Penalties for Making False or Misleading Written Statement [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Mortgage Banker Disclosure [2] State - Missing Collateral Protection Insurance Notice [TXH] Home Loan Provision: No evidence found that TX 50(a)(6) loan is reviewed by a Texas attorney prior to closing   A 50a6 violation may lead to forfeiture of all principal and interest. State - NC RC C C C
73924619 3 [3] Finance Charge underdisclosed >$35 for Refinance [3] HUD-1 Incomplete Final HUD not signed by the borrower or stamped by settlement agent. Finance charges under disclosed by $118.91 which exceeds the $35 tolerance for refinance transactions. Unable to determine under disclosure due to missing TIL itemization of amount financed; There is a Lender credit on line 204 for $737.68 which is un-itemized therefore excluded. YES Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is within the SOL. TR HUD Deficiency RD D D D
73964997 3 [3] TIL Missing [3] ROR Missing [2] Credit Score Disclosure Not Present [2] State - Missing Anti-Coercion Notice [2] State - Missing Disclosure of Terms of Mortgage Application [2] State - Missing Rate Lock Disclosure [2] State - Missing Oral Agreement Notice [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TR TIL Deficiency RB B B B
73987087 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] State - Missing Commitment Letter [2] State - Missing Disclosure of Terms of Mortgage Application [2] State - Missing Lock In Disclosure [2] State - Missing Virginia Insurance Disclosure [2] State - Missing Choice of Settlement Agent Disclosure         RB B B B
74063595 3 [3] TIL Missing [3] ROR Missing [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] State - Missing Anti-Coercion Notice [2] State - Missing Broker Agreement [2] State - Missing Pre-Application Dislcosure [2] State - Missing Notice of Material Change of Mortgage Loan Terms [2] Initial GFE Missing [2] Initial TIL Missing   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TR Indeterminable RD D D D
74088622 2 [2] Credit Score Disclosure Not Present [2] State - Missing Interest Rate Lock/Float Information [2] State - Missing Lock In Agreement         RB B B B
74154956 3 [3] Finance Charge underdisclosed >$35 for Refinance [3] ROR Incorrect Form - Non Lender to Lender Not On H8/G8 [2] State - Missing Choice of Settlement Agent Disclosure [2] Initial TIL Missing [2] Affiliated Business Doc Missing [2] State - Missing Commitment Letter [2] State - Missing Disclosure of Terms of Mortgage Application [2] State - Missing Lock In Disclosure [2] State - Missing Virginia Insurance Disclosure Finance charges under disclosed by $140.75 which exceeds the $35 tolerance for refinance transactions. Unable to determine under disclosure due to missing itemization of amount financed. ROR incorrect form used for non lender to lender refinance, H8 or G8 form not used.   Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. 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. The loan is outside the SOL. TILA SOL Expired RB B B B
74247728 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] Credit Score Disclosure Not Present [2] State - Missing Interest Rate Disclsoure [2] State - Missing Notice of Expiration of Loan Commitment [2] State - Missing Prevailing Commitment Disclosure [2] State - Pre-Application Disclosure Statement [2] State - Missing Borrower's Choice of Attorney Disclosure [2] State - Missing Junior / Subordinate Lien Disclosure         RB B B B
74438309 3 [3] ROR Violation Funding date is prior to or equals the ROR End Date [2] State - Missing Notice to Cosigner [2] State - Missing Waiver of Title Insurance Disclosure [2] HMDA-reportable rate spread (1/1/04-10/1/09) ROR executed by XXX 06/XX/2007 with expiration of rescission period noted as 06/XX/2007. HUD reflects a funding date of 06/XX/2007, equal to the rescission period expiration date, and 5 days of interest was credited which coincides with a 06/XX/2007 funding date.   ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA SOL Expired RB B B B
74526923 3 [3] TIL Missing [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Application Addedum stating applicant, if married, may apply for a separate account [2] State - Missing Consumer Credit Score Disclosure [2] State - Missing Fair Lending Notice [2] State - Missing Hazard Insurance Disclosure [2] State - Missing Comparison of Sample Mortgage Features: Typical Mortgage [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Domestic Partnership Affidavit [2] State - Missing Impound Authorization Disclosure [2] State - Missing Interim Interest Disclosure [2] Initial GFE Missing [2] Initial TIL Missing   YES   TR Indeterminable RD D D D
74545867 1           RA A A A
74548315 1           RA A A A
74565481 1           RA A A A
74656315 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
74721140 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
74815797 3 [3] APR Tolerance UnderDisclosed 0.125 [3] Finance Charge underdisclosed >$100 for Purchase APR under disclosed by .3120 which exceeds the .125 tolerance. Finance charges under disclosed by $9055.11 which exceeds the $100 tolerance for purchase transactions. Under disclosure due to final payment stream on TIL reflecting a MI payment of $111.92 (.67%) for 12 payments rather than 120 payments as reflected on the MI cert in file.   APR/Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
74949208 2 [2] Affiliated Business Doc Missing [2] State - Missing Interim Interest Disclosure         RB B B B
75038665 1           RA A A A
75052801 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
75064192 1           RA A A A
75078200 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] Credit Score Disclosure Not Present [2] State - Missing Residential Property Disclosure / Homeowner's Certification of Principal Residence [2] State - Missing Home Buyers Property Tax Payment Option [2] State - Missing Wet Settlement / Delivery of Net Proceeds Authorization [2] State - Missing Disclosure of Seller-Paid Fees [2] State - Missing First Time Home Buyer Affidavit [2] State - Missing Licensee Information or Affidavit of Exemption         RB B B B
75156877 2 [2] State - Missing Application Disclosure [2] State - Missing Net Tangible Benefit Worksheet         RB B B B
75202212 2 [2] Initial GFE Date not within 3 days of Initial Application Date [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RB B B B
75230331 2 [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] Initial GFE Missing         RB B B B
75282484 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [2] Initial TIL Missing         RB B B B
75437223 1           RA A A A
75441218 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [2] State - Missing cautionary notice pursuant to AL Code Section 5-19-6(a) on Note [2] Initial TIL Missing         RB B B B
75448719 3 [3] Federal Higher-Priced Mortgage Loan [3] Missing Certificate of Compliance/Exemption from IL Predatory Lending Database Program [2] HMDA-reportable rate spread (10/1/09 and later) [2] Loan is subject to IL Predatory Lending Database Program [2] Affiliated Business Doc Missing [2] State - Missing Description of Underwriting Criteria and Required Documentation [2] State - Missing Commitment Letter Federal Higher-Priced Mortgage Loan - stated APR of 6.857% and audited APR of 6.8568% exceed the HPML threshold of 6.37% (1.5% over applicable APOR, 4.87%). Loan appears to comply with repayment ability and prepayment penalty restrictions and requirements applicable to federal HPMLs. Loan is subject to IL predatory Lending Database Program. Certificate of Exemption from IL predatory Lending Database Program is not in file Loan is subject to IL predatory Lending Database Program. Certificate of Exemption from IL predatory Lending Database Program is not in file.   Federal Higher-Priced Mortgage Loan - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. State - NC RC C C C
75543606 3 [3] TIL Missing [3] HUD-1 Missing [2] State - Missing Mortgage Consumer Disclosure [2] State - Missing Rate Lock [2] State - Missing Application Disclosure [2] State - Missing Freedom to Choose / Anti-Coercion Disclosure [2] Initial GFE Missing [2] Initial TIL Missing   NO   TNR Testing Not Required RD D D D
75612816 2 [2] Initial TIL Missing [2] Credit Score Disclosure Not Present         RB B B B
75787192 2 [2] Initial GFE Missing [2] Initial TIL Missing [2] State - Missing Comparison of Sample Mortgage Features: Typical Mortgage [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RB B B B
75819756 3 [3] TIL Incomplete [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial GFE Missing Final TIL incomplete due to being signed on closing date however marked preliminary. YES   TR Indeterminable RD D D D
75840947 1           RA A A A
75842711 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [2] State - Missing Attorney Disclosure         RB B B B
75846509 1           RA A A A
75894235 1           RA A A A
75905030 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Initial GFE Date not within 3 days of Initial Application Date [2] Credit Score Disclosure Not Present [2] State - Missing Application Addedum stating applicant, if married, may apply for a separate account [2] State - Missing Consumer Credit Score Disclosure [2] State - Missing Fair Lending Notice [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Interim Interest Disclosure [2] State - Missing Home Equity Loan Disclosure     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
76008185 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] Affiliated Business Doc Missing         RB B B B
76055034 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Dual Status / Dual Capacity Disclosure         RB B B B
76123862 2 [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Domestic Partnership Affidavit [2] State - Missing Home Equity Loan Disclosure         RB B B B
76142788 2 [2] Initial TIL Missing         RB B B B
76200858 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
76213741 3 [3] HUD-1 Incomplete [2] Affiliated Business Doc Missing [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09) HUD in file is a signed estimated copy and not signed by the borrower or stamped by settlement agent. NO   TNR Testing Not Required RD D D D
76257359 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
76257536 2 [2] State - Missing Application Disclosure [2] State - Missing Right to Choose Insurance Provider [2] State - Missing Affidavit of Affixation (of manufactured home) [2] State - Missing Rate Lock [2] State - Missing Title Insurance Notice [2] State - Missing Separate and distinct Prepayment Penalty Disclosure on the Note [2] State - Missing Documentation of Fees paid to Third Parties [2] State - Missing Licensee Name Number and NMLS Unique Identifier on the application         RB B B B
76285797 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial GFE Date not within 3 days of Initial Application Date [2] Initial TIL Missing         RB B B B
76323813 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Affiliated Business Doc Missing [2] State - Missing Impound Authorization Disclosure [2] State - Missing Interim Interest Disclosure [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
76427154 2 [2] Initial TIL Missing [2] State - Missing Notice of Expiration of Loan Commitment [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Borrower's Choice of Attorney Disclosure         RB B B B
76448768 3 [3] APR Tolerance UnderDisclosed 0.125 [3] Finance Charge underdisclosed >$100 for Purchase [2] HMDA-reportable rate spread (1/1/04-10/1/09) APR under disclosed by .3338 which exceeds the .125 tolerance. Finance charges under disclosed by $43,371.03 which exceeds the $100 tolerance for purchase transactions. The Lender used a lower Index. The lowest Index available in our look-back is 5.28%.   APR/Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
76478858 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
76479878 2 [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Acknowledgment of Receipt of Home Mortgage Loan Informational Document / Attorney General Information Statement [2] State - Missing Mortgage Loan Origination Dislcosure [2] State - Missing Anti-Discrimination Notice [2] State - Missing Attorney General Information Statement [2] State - Missing High Loan to Value Disclosure in the Mortgage Loan Disclosure Statement [2] State - Missing Statutory Authority Disclosure [2] State - Missing Notice of Escrow of Taxes and Regular Monthly Payment [2] State - Missing Closing Statement / Closing Disclosure [2] State - Missing Nature of Relationship and Notice to Borrower in the Mortgage Loan Originator Disclosure / Addendum to GFE         RB B B B
76490231 3 [3] [GA] Home Loan Provision: Mandatory arbitration clause found on Note, no indication of whether acceptance of arbitration agreement is a condition to extend credit. GA Fair Lending Act as amended by Senate Bill 53 prohibits mandatory arbitration clause on GA home loans. [2] State - Missing Waiver of Borrower's Rights [2] State - Missing Right to Select Attorney Disclosure [2] Initial TIL Missing [GA] Home Loan Provision: Mandatory arbitration clause found on Note, no indication of whether acceptance of arbitration agreement is a condition to extend credit. GA Fair Lending Act as amended by Senate Bill 53 prohibits mandatory arbitration clause on GA home loans.     State - NC RC C C C
76572758 1           RA A A A
76572942 3 [3] TIL Missing [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure [2] State - Missing Rate Lock [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)   NO   TNR Testing Not Required RB B B B
76581946 3 [3] Violation of TX Equity Out 12 Day Cooling-Off Period [3] [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure was not in file, unable to verify compliance of TX50a6 12 day cooling off period. [3] [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice of 3-day Right of Rescission signed and dated at time of closing not in file. [3] [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure was not in file, unable to verify compliance of TX50a6 12 day cooling off period. [3] [TXH] Home Loan Provision:No evidence found that TX 50(a)(6) loan is reviewed by a Texas attorney prior to closing. [3] ROR Missing [2] Credit Score Disclosure Not Present [2] State - Missing Notice of Penalties for Making False or Misleading Written Statement [2] Initial GFE Missing [2] Initial TIL Missing [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure was not in file, unable to verify compliance of TX50a6 12 day cooling off period. [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure was not in file, unable to verify compliance of TX50a6 12 day cooling off period. [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure was not in file, unable to verify compliance of TX50a6 12 day cooling off period. [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice of 3-day Right of Rescission signed and dated at time of closing not in file. [TXH] Home Loan Provision:No evidence found that TX 50(a)(6) loan is reviewed by a Texas attorney prior to closing.   ROR - 3yrs for rescindable transactions. The loan is outside the SOL. A 50a6 violation may lead to forfeiture of all principal and interest. A 50a6 violation may lead to forfeiture of all principal and interest. A 50a6 violation may lead to forfeiture of all principal and interest. State - NC RC C C C
76602504 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Impound Authorization Disclosure         RB B B B
76606679 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [2] State - Missing Hazard Insurance Disclosure [2] State - Missing Comparison of Sample Mortgage Features: Typical Mortgage [2] State - Missing Mortgage Broker Agreement [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Finance Lender Information Disclosure [2] State - Missing Impound Authorization Disclosure [2] State - Missing Interim Interest Disclosure [2] Initial TIL Missing         RB B B B
76628891 2 [2] State - Missing Domestic Partnership Affidavit [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
76629731 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Cover Page / Social Security Disclosure [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
76710232 3 [3] Finance Charge underdisclosed >$100 for Purchase [2] State - Missing Mortgage Consumer Disclosure [2] State - Missing Rate Lock [2] State - Missing Application Disclosure [2] State - Missing Freedom to Choose / Anti-Coercion Disclosure [2] Initial TIL Date not within 3 days of Initial Application Date Finance charges under disclosed by $247.49 which exceeds the $100 tolerance for purchase transactions. TIL Itemization did not disclose the closing fee of $275 as prepaid finance charge.   Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
76797557 2 [2] State - Missing Borrower's Bill of Rights [2] State - Missing Insurance Disclosure / Right to Choose Insurance Provider [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
76811958 3 [3] Finance Charge underdisclosed >$35 for Refinance [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial GFE Missing Finance charges under disclosed by $84.04 which exceeds the $35 tolerance for refinance transactions. Unable to determine under disclosure due to missing completeTIL itemization.   APR/Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
76884538 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
76952540 1           RA A A A
76959381 3 [3] TIL Missing [3] ROR Missing [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing MD Finance Agreement [2] State - Missing Residential Property Disclosure / Homeowner's Certification of Principal Residence [2] State - Missing Home Buyers Property Tax Payment Option [2] State - Missing MD No Escrow Account Disclosure [2] State - Missing Right to Choose Attorney or Title Insurance Company [2] State - Missing Wet Settlement / Delivery of Net Proceeds Authorization [2] State - Missing Disclosure of Seller-Paid Fees [2] State - Missing First Time Home Buyer Affidavit [2] State - Missing Licensee Information or Affidavit of Exemption [2] State - Missing Net Tangible Benefit Worksheet [2] State - Missing Office of Finance, Treasury Division Finance Affidavit [2] State - Missing MD Notice of Housing Counseling and Services disclosure [2] Initial GFE Missing [2] Initial TIL Missing   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TR Indeterminable RD D D D
77088553 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial GFE Date not within 3 days of Initial Application Date         RB B B B
77145048 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Application Disclosure [2] Initial TIL Missing         RB B B B
77179588 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
77181324 3 [3] [FEDSP] Covered Loan Provision: Missing documentation utilized to verify income, assets, and current obligations. [3] Federal Higher-Priced Mortgage Loan [2] Payment value(s) in TIL Rate/Payment Disclosure inaccurate [2] HMDA-reportable rate spread (10/1/09 and later) [2] Initial GFE Missing [2] Initial TIL Missing [2] State - Missing Anti-Coercion Notice [2] State - Missing Lock In Agreement [FEDSP] Covered Loan Provision: Missing documentation utilized to verify income, assets, and current obligations. Federal Higher-Priced Mortgage Loan. Stated APR (4.25%) and Audited APR (4.2567%) exceed the HPML threshold (1.5% over applicable APOR, 2.72%) by 0.03% and 0.0367% respectively. Loan is a federal higher-priced mortgage loan and as such, must comply with applicable repayment ability, prepayment penalty, and escrow restrictions and requirements. Unable to determine repayment ability due to missing income/asset documentation. Final TIL reflects P&I Payment of $9209.24. Calculated P&I Payment is $9209.25. Variance of $.01 appears to be a rounding issue but since RegZ does not allow for tolerance, JCIII is reporting exception and will leave it at client's discretion to waive.     FHPML - NC RC C C C
77220998 3 [3] ROR Missing [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Credit Score Disclosure Not Present [2] State - Missing Anti-Coercion Notice [2] State - Missing Disclosure of Terms of Mortgage Application [2] State - Missing Rate Lock Disclosure [2] State - Missing Oral Agreement Notice [2] Initial GFE Missing     ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
77223599 3 [3] TIL Missing [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] State - Missing Appraisal Notice [2] Initial GFE Missing   NO   TNR Testing Not Required RD D D D
77266341 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date         RB B B B
77282658 3 [3] APR Tolerance UnderDisclosed 0.125 [3] Finance Charge underdisclosed >$35 for Refinance [3] TIL Incomplete [2] Affiliated Business Doc Missing [2] Initial TIL Missing [2] Evidence of Single Premium Credit Insurance With Disclosure [2] HMDA-reportable rate spread (1/1/04-10/1/09) APR under disclosed by 1.1687 which exceeds the .125 tolerance. Evidence of single credit life insurance with a monthly payment of $59.58 and annual premium of $714.96. Insurance is optional. Final TIL is executed by borrower at closing; however, reflects estimate Finance Charge and Total Payment figures. Finance charges under disclosed by $78,741.20 which exceeds the $35 tolerance for refinance transactions. Lender TIL reflects decreasing payments for a Pay Right Rewards Program that assumes each payment will be made on time; however, audited TIL makes no assumption of on-time payments. TESTED APR - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TR Tested RB B B B
77310624 3 [3] Finance Charge underdisclosed >$100 for Purchase [2] State - Missing Notice to Purchaser-Mortgagor Finance charges under disclosed by $16,775.54 which exceeds the $100 tolerance for purchase transactions. Appears a lower index was used than was available in the look-back period. Lowest index available is 3.17%.   APR/Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
77345483 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
77345944 2 [2] Credit Score Disclosure Not Present [2] State - Missing Pre-Application Dislcosure [2] State - Missing Lock In Agreement [2] Initial GFE Missing         RB B B B
77355242 3 [3] HUD-1 Estimated [2] Affiliated Business Doc Missing [2] State - Missing Guaranty Terms Agreement [2] State - Missing Right to Choose Insurance Provider [2] State - Missing Tangible Net Benefit Disclosure [2] HMDA-reportable rate spread (1/1/04-10/1/09) Estimated HUD in file is executed by the borrower and certified by the settlement agent. YES   TR Indeterminable RD D D D
77369483 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing MD Finance Agreement [2] State - Missing Application Disclosure [2] State - Missing Right to Choose Attorney or Title Insurance Company [2] State - Missing Wet Settlement / Delivery of Net Proceeds Authorization [2] State - Missing Disclosure of Seller-Paid Fees [2] State - Missing Licensee Information or Affidavit of Exemption         RB B B B
77383144 1           RA A A A
77603721 2 [2] Initial GFE Date not within 3 days of Initial Application Date [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure [2] Initial TIL Missing         RB B B B
77698908 2 [2] State - Missing Lock In Agreement         RB B B B
77850210 2 [2] Credit Score Disclosure Not Present [2] State - Missing Acknowledgment of Receipt of Copies of Signed Loan Documents         RB B B B
77966877 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] State - Missing Anti-Discrimination Notice [2] State - Missing Attorney General Information Statement [2] State - Missing High Loan to Value Disclosure in the Mortgage Loan Disclosure Statement [2] State - Missing Statutory Authority Disclosure         RB B B B
78005159 2 [2] Credit Score Disclosure Not Present         RB B B B
78018978 3 [3] Finance Charge underdisclosed >$100 for Purchase [2] Initial TIL Missing [2] Initial GFE Missing Finance charges under disclosed by $100.02 which exceeds the $100 for purchase. TIL Itemization did not disclose settlement fees: Closing Fee $130.00, Courier fee $70.00 and Wire Transfer fee $20.00 as prepaid finance charges. There is a Seller credit on page one of HUD for $391.45 which is not itemized therefore excluded.     TILA SOL Expired RB B B B
78067082 2 [2] Credit Score Disclosure Not Present [2] State - Missing Mortgage Consumer Disclosure [2] State - Missing Freedom to Choose / Anti-Coercion Disclosure [2] State - Missing or Incomplete Variable Rate Disclosure [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
78070781 3 [3] State Grace Period Below Minimum [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Credit Score Disclosure Not Present [2] State - Missing Choice of Insurance Disclsoure [2] Initial GFE Missing Grace period of 10 days is below the minimum of 15 days per the state of Oregon.   TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
78112605 2 [2] State - Missing Affidavit of Borrower Under Residential Mortgage Act [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RB B B B
78113122 2 [2] Affiliated Business Doc Missing         RB B B B
78126008 3 [3] Finance Charge underdisclosed >$35 for Refinance [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Attorneys' Fees Disclosure [2] State - Missing Guarantee Of Loan Program [2] State - Missing Licensee Information or Affidavit of Exemption [2] State - Missing Net Tangible Benefit Worksheet [2] State - Missing Written Acknowledgement of Delivery of the Note [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date Finance charges under disclosed by $146.75 which exceeds the $35 tolerance for refinance transactions. Unable to determine under disclosure due to missing itemization of amount financed.   Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
78140943 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
78151088 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Initial TIL Missing         RB B B B
78208326 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
78240627 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Credit Score Disclosure Not Present [2] State - Missing Commitment Letter [2] State - Missing Disclosure of Terms of Mortgage Application [2] State - Missing Virginia Insurance Disclosure [2] State - Missing Dual Capacity Disclosure [2] State - Missing signed Notice of Mortgage Broker Fee [2] State - Missing Appraisal Notice         RB B B B
78311062 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Commitment Disclosure         RB B B B
78339091 3 [3] TIL Missing [3] ROR Missing [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] State - Missing Commitment Letter [2] State - Missing Rate Lock [2] State - Missing Application Disclosure [2] State - Missing Freedom to Choose / Anti-Coercion Disclosure [2] Initial GFE Missing [2] Initial TIL Missing   YES ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TR Indeterminable RD D D D
78352169 3 [3] ROR Missing [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09)     ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA SOL Expired RB B B B
78367472 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
78402300 1           RA A A A
78426753 2 [2] State - Missing Mortgage Banker Disclosure [2] State - Missing Loan Agreement Rider [2] GFE1 Written list of service providers not given to borrower [2] RegX Violation: Borrower was not provided with a current list of local homeownership counseling organizations within 3 days of application [1] HUD QM APR Test - APR below HUD QM APR Threshold: Safe Harbor [1] QM Loan - HUD QM Rule (Conditional) [1] TILA Designation: Safe Harbor QM - HUD QM Rule (Conditional - Proof of Insurance required) Homeownership Counseling Organizations form in file is not dated; therefore we are not able to determine if it was provided to borrower within 3 days of the application.       RB B B B
78429863 2 [2] Affiliated Business Doc Missing [2] State - Missing Mortgage Consumer Disclosure [2] State - Missing Commitment Letter [2] State - Missing Rate Lock [2] State - Missing Application Disclosure [2] State - Missing Freedom to Choose / Anti-Coercion Disclosure         RB B B B
78464412 2 [2] Credit Score Disclosure Not Present         RB B B B
78492228 2 [2] Credit Score Disclosure Not Present [2] Initial TIL Missing         RB B B B
78512610 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [2] State - Missing Anti-Coercion Notice [2] State - Missing Pre-Application Dislcosure [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
78547638 2 [2] State - Missing Prepayment Penalty Disclosure [2] State - Missing Non Agency Disclosure         RB B B B
78567417 3 [3] TIL Missing [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Pre-Application Dislcosure [2] Initial GFE Missing [2] Initial TIL Missing   YES   TR TIL Deficiency RB B B B
78575104 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Pre-Application Dislcosure [2] Initial TIL Missing         RB B B B
78693301 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
78797310 2 [2] Affiliated Business Doc Missing         RB B B B
78803268 3 [3] TIL Incomplete [2] Initial GFE Missing Final TIL was signed by the borrower at closing, however, reflects estimated APR, finance charges, amount financed and total payment figures. TESTED   TR Tested RB B B B
78861473 2 [2] Credit Score Disclosure Not Present [2] State - Missing Application Disclosure [2] State - Missing Notice of Expiration of Loan Commitment [2] State - Missing Prevailing Commitment Disclosure [2] State - Missing Tax Escrow Account Designation [2] State - Missing Lock-In Agreement [2] State - Missing Appraisal and Consumer Report Notice [2] State - Missing Borrower's Choice of Attorney Disclosure         RB B B B
78895179 1           RA A A A
79040534 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] Affiliated Business Doc Missing         RB B B B
79099516 1           RA A A A
79104656 2 [2] Initial TIL Missing [2] Initial GFE Date not within 3 days of Initial Application Date         RB B B B
79116654 2 [2] Initial TIL Missing         RB B B B
79211949 3 [3] Finance Charge underdisclosed >$35 for Refinance [2] Affiliated Business Doc Missing Finance charges under disclosed by $16258.98 which exceeds the $35 tolerance for refinance transactions. It appears a lower Index was used at origination than the 3.04% Index available within the look-back period.   APR/Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
79214448 3 [3] HUD-1 Incomplete [2] State - Missing Application Addedum stating applicant, if married, may apply for a separate account [2] State - Missing Consumer Credit Score Disclosure [2] State - Missing Fair Lending Notice [2] State - Missing Hazard Insurance Disclosure [2] State - Missing Mortgage Loan Disclosure Statement (DRE) [2] State - Missing DRE Advance Fee Agreement [2] State - Missing Comparison of Sample Mortgage Features: Typical Mortgage [2] State - Missing Mortgage Broker Agreement [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate [2] State - Missing Finance Lender Information Disclosure [2] State - Missing Interim Interest Disclosure [2] Initial GFE Missing [2] Initial TIL Missing [2] HMDA-reportable rate spread (1/1/04-10/1/09) Hud is incomplete due to line 1002 $82.10 is incorrectly designated as 2 months MIP premium. Should have been entered in line 1001 as Hazard Insurance reserves. TESTED   TR Tested RB B B B
79228492 3 [3] HUD-1 Missing [2] Credit Score Disclosure Not Present [2] State - Missing Right to Select Attorney Disclosure   YES   TR Indeterminable RD D D D
79231851 2 [2] Credit Score Disclosure Not Present [2] State - Missing Fair Lending Notice [2] Initial GFE Missing         RB B B B
79255201 2 [2] Affiliated Business Doc Missing [2] State - Missing Borrower Information Document [2] State - Missing Rate and Points Lock/Float Agreement [2] State - Missing Description of Underwriting Criteria and Required Documentation [2] State - Missing Collateral Protection Act Disclosure [2] State - Missing Notice of Choice of Agent or Insurer [2] Initial TIL Missing         RB B B B
79279097 2 [2] Initial GFE Date not within 3 days of Initial Application Date [2] Affiliated Business Doc Missing [2] State - Missing Borrower Information Document         RB B B B
79308271 2 [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
79351656 2 [2] Affiliated Business Doc Missing         RB B B B
79412377 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] State - Missing Broker Compensation Disclosure [2] State - Missing Interest Rate Disclsoure [2] State - Missing Insurance Disclsoure [2] State - Missing Notice of Expiration of Loan Commitment [2] State - Missing Lock-In Agreement [2] State - Missing Appraisal and Consumer Report Notice [2] State - Missing Borrower's Choice of Attorney Disclosure [2] Initial GFE Missing         RB B B B
79430946 2 [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
79442301 2 [2] Affiliated Business Doc Missing         RB B B B
79449130 2 [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Borrower's Bill of Rights [2] State - Missing Consumer Caution and Counseling Disclosure [2] State - Missing Rate Lock [2] Initial GFE Missing         RB B B B
79464430 3 [3] ROR Missing [2] Affiliated Business Doc Missing [2] State - Missing Broker Agreement [2] State - Missing Loan Product Choice / Prepayment Penalty Disclosure [2] State - Missing Escrow Account Disclosure Agreement [2] State - Missing Loan Brokerage Disclosure Statement [2] Initial GFE Missing     ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA SOL Expired RB B B B
79473931 2 [2] Initial TIL Date not within 3 days of Initial Application Date [2] Initial GFE Date not within 3 days of Initial Application Date [2] State - Missing Notice of Expiration of Loan Commitment [2] State - Missing Prevailing Commitment Disclosure [2] State - Missing Tax Escrow Account Designation [2] State - Missing Lock-In Agreement [2] State - Missing Appraisal and Consumer Report Notice [2] State - Missing Borrower's Choice of Attorney Disclosure         RB B B B
79498890 2 [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
79502823 3 [3] Finance Charge underdisclosed >$35 for Refinance [2] State - Missing Anti-Coercion Notice [2] State - Missing Choice of Attorney disclosure [2] State - Missing Amortization Information Disclosure Finance charges under disclosed by $2,209.48 which exceeds the $35 tolerance for refinance transactions. Unable to determine under disclosure due to missing itemization of amount financed.   Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
79510858 2 [2] State - Missing Acknowledgment of Receipt of Good Faith Estimate         RB B B B
79570121 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
79593061 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Acknowledgment of Receipt of Home Mortgage Loan Informational Document / Attorney General Information Statement [2] State - Missing Mortgage Loan Origination Dislcosure [2] State - Missing Anti-Discrimination Notice [2] State - Missing Attorney General Information Statement [2] Missing Notice of Change in Mortgage Terms / Revised Mortgage Loan Originator Disclosure [2] State - Missing Ohio Business Relationship Disclosure Notice / Conflict of Interest Disclosure [2] State - Missing Statutory Authority Disclosure [2] State - Missing Notice of Escrow of Taxes and Regular Monthly Payment [2] State - Missing Closing Statement / Closing Disclosure [2] State - Missing Nature of Relationship and Notice to Borrower in the Mortgage Loan Originator Disclosure / Addendum to GFE [2] Initial GFE Missing [2] Initial TIL Missing         RB B B B
79636865 3 [3] Finance Charge underdisclosed >$35 for Refinance [2] Affiliated Business Doc Missing [2] State - Missing Rate and Points Lock/Float Agreement [2] State - Missing Description of Underwriting Criteria and Required Documentation [2] State - Missing Commitment Letter [2] Initial TIL Missing Finance charges under disclosed by $50 which exceeds the $35 tolerance for refinance transactions. Unable to determine under disclosure due to missing itemization of amount financed.   Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
79677959 2 [2] Credit Score Disclosure Not Present [2] Initial GFE Missing         RB B B B
79683808 3 [3] Finance Charge underdisclosed >$100 for Purchase [2] State - Missing Notice of Consumers Right to Obtain a Security Freeze Finance charges under disclosed by $1617.54 which exceeds the $100 tolerance for purchase transactions. The under disclosure appears to stem from the second renewal mortgage insurance premium calculated at .169% compared to audit's calculated renewal rate of .55%.   APR/Finance Charge - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B
79742708 2 [2] State - Missing Impound Authorization Disclosure         RB B B B
79747720 2 [2] State - Missing Cover Page / Social Security Disclosure [2] Initial GFE Missing         RB B B B
79754048 2 [2] Initial TIL Missing [2] Initial GFE Date not within 3 days of Initial Application Date         RB B B B
79798128 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09)         RA A A A
79821091 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Affiliated Business Doc Missing [2] State - Missing Comparison of Sample Mortgage Features: Typical Mortgage [2] State - Missing Interim Interest Disclosure         RB B B B
79824191 2 [2] Credit Score Disclosure Not Present [2] Initial TIL Missing         RB B B B
79859241 2 [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Affiliated Business Doc Missing         RB B B B
79903924 2 [2] Credit Score Disclosure Not Present [2] Initial GFE Missing         RB B B B
79924085 3 [3] Violation of TX Equity Out 12 Day Cooling-Off Period [3] [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure was missing page 2 of 2, unable to verify compliance of TX50a6 12 day cooling off period. [3] [TXH] Home Loan Provision: No evidence found that TX 50(a)(6) loan is reviewed by a Texas attorney prior to closing [2] State - Missing Notice of Penalties for Making False or Misleading Written Statement [2] State - Missing Complaints and Inquiries Notice [2] Initial GFE Missing [2] Initial TIL Missing [2] State - Missing Collateral Protection Insurance Notice [2] HMDA-reportable rate spread (1/1/04-10/1/09) [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [TXH] Home Loan Provision: No evidence found that TX 50(a)(6) loan is reviewed by a Texas attorney prior to closing [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure was missing page 2 of 2, unable to verify compliance of TX50a6 12 day cooling off period. [TXH] Home Loan Provision: TX 50(a)(6) DISCLOSURE: Notice Concerning Equity Loan Extensions of Credit / Home Equity Disclosure was missing page 2 of 2, unable to verify compliance of TX50a6 12 day cooling off period.   A 50a6 violation may lead to forfeiture of all principal and interest. A 50a6 violation may lead to forfeiture of all principal and interest. A 50a6 violation may lead to forfeiture of all principal and interest. State - NC RC C C C
79938439 3 [3] ROR Missing [2] State - Missing Mortgage Consumer Disclosure [2] State - Missing Commitment Letter [2] State - Missing Rate Lock     ROR - 3yrs for rescindable transactions. The loan is outside the SOL. TILA SOL Expired RB B B B
79973467 2 [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] State - Missing Attorney Disclosure [2] State - Missing Insurance Disclosure [2] State - Missing Application Disclosure [2] State - Missing Domestic Partnership Affidavit [2] State - Missing Lock In Agreement [2] State - Missing Commitment Letter [2] Initial GFE Missing         RB B B B
79997370 3 [3] Missing HELOC fee disclosures required under TILA. Unable to validate compliance with TILA HELOC Account-opening disclosure requirements. [2] Credit Score Disclosure Not Present [2] Affiliated Business Doc Missing [2] Initial GFE Missing     TILA - 1yr affirmative, 3yrs for rescindable transactions. Unlimited as a defense to foreclosure. Assignee liability. The loan is outside the SOL. TILA SOL Expired RB B B B